Title
Computation of Civil Penalties on Tax Deficiency
Law
Bir Revenue Memorandum Circular No. 46-99
Decision Date
Jun 18, 1999
BIR Revenue Memorandum Circular No. 46-99 outlines the computation of civil penalties, including a 25% surcharge and 20% interest for late payment of internal revenue taxes, as well as procedures for extra-judicial settlement of taxpayer criminal liabilities under the National Internal Revenue Code.
A

Procedure for Computing Surcharge and Interest on Deficiency or Delinquent Taxes

  • Uniform application of surcharge (25%) and interest (20% per annum) effective from January 1, 1998.
  • Computation follows illustrative examples provided to ensure consistency.

Illustrative Scenarios on Penalties and Interest

Scenario 1: Late Filing and Late Payment

  • Taxpayer who files and pays after the deadline is liable for 25% surcharge and 20% interest p.a. from due date to payment date.
  • Only one 25% surcharge is imposed, covering both late filing and payment.

Scenario 2: Filing Return Through Unauthorized Officer

  • Filing with an unauthorized internal revenue officer without Commissioner’s approval results in 25% surcharge on tax due.

Scenario 3: Willful Neglect in Late Filing and Payment

  • Willful neglect to file return incurs a 50% surcharge plus interest.

Scenario 4: Deficiency Tax Penalties

  • Upon audit, deficiency tax computed; interest of 20% p.a. imposed from original due date to payment.
  • Penalties escalate to 50% surcharge if the return is false or fraudulent.

Scenario 5: Late Payment of Deficiency Tax

  • If deficiency tax payment is late, a 25% surcharge and 20% interest p.a. on the assessed amount are imposed.

Scenario 6: Partial or Installment Payment

  • Extended payment with prior authorization: no 25% surcharge, only 20% interest on unpaid balance computed on diminishing balance basis.
  • Partial payment without authorization: 25% surcharge plus interest on entire tax amount and 20% interest on unpaid balance until paid.

Suggested Compromise Penalty in Criminal Tax Violations

  • Section 204 allows compromise of criminal violations except where cases are filed in court or involve fraud.
  • Compromise settlements for criminal tax liability are consensual and cannot be imposed without taxpayer agreement.
  • BIR may only suggest such settlements; courts uphold necessity of taxpayer consent for compromise penalties.
  • Suggested compromise penalties must conform to the schedule under Revenue Memorandum Order No. 1-90.

Effectivity and Enforcement

  • This Circular’s provisions are effective from January 1, 1998, as mandated by Section 8 of R.A. No. 8424.
  • Strict enforcement of the Circular is directed to ensure compliance.

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