Taxation can support the realization of human rights when it does not discriminate against anyone and is pursued to reduce inequality and promote social justice. Discrimination in taxation may take severalforms, but ultimately is determined by who bears the tax burden. Discrimination in direct taxation may occur when the bulk of personal income tax is sourced from fixed salary workers rather than from professionals or businessmen, as is the case in the Philippines. While Republic Act 9504 amending the National lnternal Revenue Code of 1997 exempted all workers earning the statutory minimum wage from payment of income tax, the tax exemption is automatically withdrawn if workers are granted a salary increase of any amount, even one peso. Miniscule salary increases would result in fixed wage earners paying more taxes than the additional pay they received. Discrimination in indirect taxation may occur even though all persons, regardless of income, pay exactly the same amount of tax. While the rich, in absolute terms, pay more indirect tax, in real terms, those who live in poverty "spend a much higher percentage of their minimal incomes on the goods and services that carry this tax than those with large disposable incomes. So too much reliance by a government on VAT for its revenue can end up deepening inequality in a country." (Christian Aid and SOMO, 2011) Taxation may also discriminate against women. "Tax systems can also play a role in addressing or exacerbating economic inequality between women and men. This can either be implicit or explicit... lmplicitly, an identical tax may have a differential impact on women and men because of their differing social and economic roles. For example: ... a shift from direct taxes to indirect taxes such as VAT can produce greater gender inequalities if taxes are levied on essential goods that are consumed disproportionately by female-headed households." (Christian Aid and SOMO, 2011) The issue of gender has been largely absent in Philippine tax discourse; the authors have not found any Philippine study that assessed the impact of taxation on women. This is a gap that must be filled, if the human rights based approach were to be implemented. Taxation can also promote the realization of human rights, through "repricing, or limiting public 'bads;' encouraging public 'goods,"' (Christian Aid and SOMO, 2011) also known as "corrective taxation" or "sin taxes." Taxation can promote the right to the highest attainable standard of health by making it more costly to purchase tobacco or alcohol, which have proven to be major health hazards, and are among the leading causes of mortality or morbidity in the country. lmposing taxes on petroleum products, carbon emissions and mining activities can also promote the right to a healthy environment. A key human rights function of taxation is the satisfaction of the minimum essential levels of human rights. This is because taxation can adversely affect a person's access to goods, services and facilities that comprise the minimum essential levels of a right, especially when it results in rising prices and an effective reduction in purchasing power, This is not consistent with core obligations, and is problematic to some extent in the Philippines. While the value added tax (VAT) exempts a number of goods and services related to the enjoyment of some human rights (see matrix below), it is questionable whether these exemptions actually support the satisfaction of the minimum essential levels of these rights. Take the right to adequate food. While food products, such as rice, corn, fish, livestock and poultry are exempt from VAT, transport costs to bring these items from food producing to food 62