Dunkin’ Donuts franchiser slapped

derived from the grossed-up value of the franchise fee paid to DDAI.

Golden Donuts was also said to have under-declared its royalty income by over P38 million, which was discovered by comparing royalties declared by the company in its 2007 annual income tax return vis-à-vis the royalties declared by franchisees in their own tax returns.

Moreover, the BIR said royalty income amounting to over P133 million should have been subject to regular corporate income tax.

“Analysis of the royalty income shows that by the nature or source of royalty income, it should not be treated as passive income subject GDI did,” the agency said.

Under-declarations of income or overstatements of deductions that exceed 30 percent are deemed substantial and constitute prima facie evidence of a false or fraudulent return under the Tax Code, it added

The case against Golden Do RATE program, the BIR said.

The company, meanwhile, said it “categorically denies the accusations of tax evasion for the year 2007. As a matter of fact, the tax liabilities of GDI for the said year had been settled with the Bureau of Internal Revenue as of 2012”.

“While GDI has yet to receive a copy of the complaint filed on , it appears from the news reports that the complaint was filed based on an alleged 39 percent underdeclaration of sales which arose from the attribution of sales of franchises to GDI,” it said in a statement.

The company stressed that all its franchisees were separate business entities responsible for paying their own taxes.

“GDI is a professionally-managed organization which has been 37 years. GDI is prepared to answer the tax evasion case in the proper forum,” it said.

The case against Golden Donuts is the latest setback for the Prietos, who have been forced to give up the Mile Long property talks to give up control of the

Philippine Daily Inquirer to businessman Ramon Ang, said to be