Direct duplicate or obnoxious double taxation

Double taxation means taxing the same property twice when it should be taxed only once; that is, taxing the same person twice by the same jurisdiction for the same thing. It is obnoxious when the taxpayer is taxed twice, when it should be but once. Otherwise described as direct duplicate taxation, the two taxes must be imposed on the same subject matter, for the same purpose, by the same taxing authority, within the same jurisdiction, during the same taxing period; and the taxes must be of the same kind or character. (G.R. No. 181845)

Therefore, for there to be direct duplicate taxation or obnoxious double taxation (the kind that is not allowed), the taxpayer must be made to pay tax for the same PATO: same purpose, same authority, same taxable period and same object (or property).