Are business taxes deemed to be business permit fees?

IN the recent decision of Bases Conversion and Development Authority and John Hay Management Corp. v City Government of Baguio City (BCDA v Baguio Case, GR 192694. Feb. 22, 2023), the Supreme Court stated that "[t]he payment of fees for the issuance of business permits is regulatory in nature under the local government unit's police power. It is not a tax for revenue generation. Tax-exempt entities, therefore, cannot claim to be exempted from paying fees for business permits."

In the said case, the Bases Conversion and Development Authority (the Authority) and its subsidiary, John Hay Management Corp. (JHMC), are within the John Hay Special Economic Zone. Pursuant to Section 24 of Republic Act 7916, as amended, "except for real property taxes on land owned by developers, no taxes, local or national, shall be imposed on business establishments operating within the ecozone." Based on this provision, the Authority and JHMC claimed that they cannot be made liable for "business taxes" imposed by the City of Baguio for the issuance of a business permit because it is "revenue-generating" for being based on the gross receipts from the previous fiscal year and are not regulatory in nature, and thus is a tax which they are exempt from.