Title
BIR Regs on Tax Assessment Due Process
Law
Bir Revenue Regulations No. 18-2013
Decision Date
Nov 28, 2013
BIR Revenue Regulations No. 18-2013 amends the due process requirements for issuing deficiency tax assessments, streamlining procedures for Preliminary Assessment Notices and Formal Letters of Demand while outlining the taxpayer's rights to protest and appeal.
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Amendment to Due Process in Deficiency Tax Assessment

  • Deleted the requirement for a Notice of Informal Conference.
  • Provides new procedural rules for issuance of deficiency tax assessments.

Preliminary Assessment Notice (PAN)

  • Issued after review by the Commissioner or authorized representative if sufficient basis exists for deficiency tax.
  • PAN must detail facts, laws, rules, or jurisprudence supporting the proposed assessment.
  • Taxpayer has 15 days to respond; failure to respond leads to issuance of Formal Letter of Demand and Final Assessment Notice (FLD/FAN).
  • If taxpayer disagrees and responds within 15 days, FLD/FAN issued within 15 days after response.

Exceptions to the Prior Notice (PAN) Requirement

  • No PAN required in the following cases:
    • Mathematical errors in tax computation on the return.
    • Discrepancy between tax withheld and amount remitted.
    • Automatic application of excess creditable withholding tax against estimated tax liabilities.
    • Unpaid excise tax on excisable articles.
    • Transfer/sale of articles by exempt persons to non-exempt persons.
  • FLD/FAN issued outright in these cases.

Formal Letter of Demand and Final Assessment Notice (FLD/FAN)

  • Issued by Commissioner or authorized representative.
  • Must state facts and legal basis for assessment or it is void.

Disputed Assessment—Administrative Protest and Appeal

  • Taxpayer or authorized representative may protest within 30 days of receipt of FLD/FAN.
  • Types of protest:
    • Request for Reconsideration: Reevaluation based on existing records, involves fact or law.
    • Request for Reinvestigation: Reevaluation based on new or additional evidence.
  • Protest must state type, date of assessment notice, and legal basis; else considered void.
  • Disputed and undisputed issues treated separately: undisputed issues become final and demandable.
  • For reinvestigation, supporting documents must be filed within 60 days; no time limit for reconsideration.
  • Failure to protest within 30 days renders assessment final and demandable.
  • No reconsideration or reinvestigation allowed if assessment is final.

Denial of Protest and Appeal Options

  • If protest denied in whole or part:
    • Appeal to Court of Tax Appeals (CTA) within 30 days;
    • Or file request for reconsideration to Commissioner within 30 days (no reinvestigation allowed).
  • If no action within 180 days:
    • Taxpayer may appeal to CTA within 30 days after 180-day period or await decision and appeal thereafter.
  • Election between two options is mutually exclusive.

Final Decision on Disputed Assessment (FDDA)

  • Commissioner’s decision must state facts and legal basis, and declare it final.
  • Decision void if these conditions not met.

Modes of Service of Notices

  • Personal service at registered or known address.
  • Substituted service when party is absent:
    • Leave notice with clerk or responsible person at place of business/residence.
    • If no one found, notice given to barangay official in presence of disinterested witnesses.
  • Service by mail:
    • Registered mail with return instructions.
    • Professional courier service acceptable; ordinary mail as last resort.
  • Written report under oath required for service.
  • Service to duly appointed tax agent/practitioner deemed service to taxpayer.

Amendment on Late Payment Penalties

  • Deficiency tax must be paid within prescribed time; otherwise, delinquency interest applies.
  • Detailed illustrations provided for computing surcharges, deficiency and delinquency interests.
  • Illustrations cover scenarios of late payment without protest, with protest upheld late, and with fraudulent/false returns.

Repealing Clause

  • Any inconsistent rules or parts thereof are repealed, amended, or modified accordingly.

Effectivity

  • Regulations take effect 15 days after publication in a newspaper of general circulation.

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