A tax amnesty is a general pardon or intentional
overlooking by the State (Republic of the
Philippines) of its authority to impose penalties
on persons otherwise guilty of evasion or
violation of a revenue or tax law. It partakes of an
absolute forgiveness or waiver by the government
of its right to collect what is due it and to give tax
evaders who wish to relent a chance to start with
a clean slate. A tax amnesty, much like a tax
exemption, is never favored nor presumed in
law. If granted, the terms of the amnesty, like that
of a tax exemption, must be construed strictly
against the taxpayer and liberally in favor of the
taxing authority. For the right of taxation is
inherent in government. The State cannot strip
itself of the most essential power of taxation by
doubtful words. He who claims an exemption (or
an amnesty) from the common burden must
justify his claim by the clearest grant of organic
or State law. It cannot be allowed to exist upon a
vague implication. If a doubt arises as to the
intent of the legislature, that doubt must be
resolved in favor of the State.