1.

UNIFORMITY AND EQUITY IN TAXATION

- same class, same rate

- classification of taxpayers, subject or items to be taxed

 The rule of taxation shall be uniform and equitable (Sec.28 (1), Art. III, 1987
Constitution).
 The tax is uniform when it operates with the same force and effect in every place where
the subject of it is found. "Uniformity" means all property belonging to the same class
shall be taxed alike. It does not signify an intrinsic, but simply a geographic, uniformity
(Churchill & Tait vs. Conception, 34 Phil. 969). Uniformity does not require the same
treatment; it simply requires reasonable basis for classification.
 The concept of equality in taxation requires that the apportionment of the tax burden be
more or less just in the light of the taxpayer’s ability to shoulder the tax burden and if
warranted, on the basis of the benefits received from the government. Its cornerstone
is the taxpayer’s ability to pay.

Uniformity v. equity in taxation

 The concept of uniformity in taxation implies that all taxable articles or properties of the
same class shall be taxed at the same rate.  It requires the uniform application and operation,
without discrimination, of the tax in every place where the subject of the tax is found. It does
not, however, require absolute identity or equality under all circumstances, but subject to
reasonable classification.

·                     The concept of equity in taxation requires that the apportionment of the tax burden be,
more or less, just in the light of the taxpayer’s ability to shoulder the tax burden and, if
warranted, on the basis of the benefits received from the government.  Its cornerstone is the
taxpayer’s ability to pay.