Timing of Tax Offense and Prescription Rules

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KRI REVENUE MEMORANDUM CIRCULAR NO. 101-90: Timing of Tax Offense & Prescription Rules

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Title Source: Supreme Court: Timing of Tax Offense and Prescription Rules

Law: Kri Revenue Memorandum Circular No. 101-90

Decision Date: Nov 26, 1990

The Supreme Court ruling clarifies that the cause of action for willful failure to pay deficiency tax arises only upon receipt of the final notice and demand, with a five-year prescriptive period commencing from that point, emphasizing the necessity of judicial proceedings for the offense to be considered actionable.

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