MANILA - The Department of Justice (DOJ) has set hearings for the preliminary investigation into the tax evasion complaint against Rappler Holdings Corporation (RHC) and two of its top executives.

Subpoenas have been sent for the April 24 and May 7 hearings to Rappler President Maria Ressa and treasurer James Bitanga for the P133.84-million (P133,841,305.75) tax case, covering taxable year 2015, filed by the Bureau of Internal Revenue (BIR).

Certified Public Accountant Noel A. Baladiang of R.G. Manabat & Co., who was charged for signing and certifying the financial statements of RHC, was also sent summons.

The BIR filed the complaint against the website's holding company, Rappler Holdings, over its alleged failure to pay taxes on the sale of Philippine Depositary Receipts.

“On various dates, RHC purchased common shares from Rappler, Inc. amounting to P19,245,975.00. RHC subsequently issued and sold Philippine Depositary Receipts (PDRs) on various dates to two foreign juridical entities for a total consideration of P181,658,758.67. RHC used the same common shares it purchased from Rappler, Inc. as the underlying asset/share of the PDRs," the BIR complaint stated.

“The purchase of the shares and the subsequent sale of shares through the issuance of the PDRs for profit that transmitted economic rights (e.g. financial returns or cash distributions) derived from the equity of Rappler Inc. to the PDR holders is proof that RHC is engaged in the purchase of securities and resale thereof to customers."

Rappler CEO Maria Ressa earlier said her company goes "overboard" when paying taxes.

• Rappler goes 'overboard' with tax payments, Ressa says