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In June 20, 2018, Mandela City, a city located on the south of Armenia City amended its Revenue Code to include a new provision imposing

In June 20, 2018, Mandela City, a city located on the south of Armenia City amended its Revenue Code to include a new provision imposing a tax on every sale of merchandise by a wholesaler based on the total selling price of the goods, inclusive of value-added taxes (VAT). ARGUS Corp., a wholesaler operating within Mandela City, challenged the new provision based on the following contentions: 1. the new provision is a form of prohibited double taxation because it essentially amounts to Mandela City imposing VAT which was already being levied by the national government; and 2. since the tax being imposed is akin to VAT, it is beyond the power of Mandela City to levy the same. Rule on each of ARGUS Corp.'s contentions.


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