Title
Amendment to Exchange of Info Rules
Law
Bir Revenue Regulations No. 3-2014
Decision Date
Feb 11, 2014
The amendment to Section 10 of Revenue Regulations No. 10-2010 mandates that taxpayers be notified within 60 days of a foreign tax authority's request for information from financial institutions, unless such notification could jeopardize the investigation, in which case notification is extended to six months.
A

Q&A (BIR REVENUE REGULATIONS NO. 3-2014)

The main purpose is to amend Section 10 of Revenue Regulations No. 10-2010 concerning the exchange of information between the Philippines and foreign tax authorities.

A taxpayer must be notified in writing within sixty (60) days from receipt of the request by the Commissioner.

If notification within sixty (60) days would undermine the chances of success of the investigation conducted by the foreign tax authority, the notification period can be extended to a maximum of six (6) calendar months from receipt of the request.

Section 244 in relation to Section 4 of the National Internal Revenue Code of 1997, as amended, empower the issuance.

It covers the rules concerning the exchange of information held by financial institutions pursuant to international conventions or agreements on tax matters.

All revenue issuances or parts thereof inconsistent with these regulations are repealed, amended, or modified accordingly.

The regulations took effect immediately upon issuance.

The Secretary of Finance, Cesar V. Purisima, and the Commissioner of Internal Revenue, Kim S. Jacinto-Henares, signed and approved the regulations.

They form the legal basis for foreign tax authorities to request exchange of information held by Philippine financial institutions.


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