Download as DOCX, PDF, TXT or read online from Scribd
Download as docx, pdf, or txt
You are on page 1/ 1
BIR issues LOA A
Audit or Tax Investigation
by Revenue Officer
Is there a decision by NO the CIR within 180d from the filing of the NO Action will not Is there sufficient basis protest? to assess deficiency be pursued YES tax? There is an inaction
YES
PAN shall be issued, Is the decision of the B
subject to exemptions CIR in favor of the YES taxpayer?
Taxpayer has 15d from
receipt to reply/respond Assessment NO to PAN shall be dismissed Protest is *For inaction by the denied in NO Taxpayer will CIR, the 180d is whole or in Is there a counted from the reply/response? be in default part time the protest is filed YES Taxpayer may For inaction by the 1. appeal to the CTA within 30d CIR’s rep > 180d from the denial (Judicial Appeal) from: Is the NO FLD/FAN shall reply/response be issued OR YES 1. date of filing of meritorious? 2. elevate his protest through a protest (request for request for reconsideration to the reconsideration) Assessment Taxpayer may file CIR within 30d from the decision shall be a Protest within (Administrative Appeal) 2. date of dismissed 30d from receipt submission of the required relevant of the FLD/FAN supporting documents (request Is there an for reinvestigation) appeal to the CTA? NO Assessment shall Is there a protest? be final, executory NO & demandable YES
Is there a request YES Is the protest a for request for File a Petition for reconsideration? NO Reconsideration? Review under Rule 42 (Judicial Assessment shall Appeal) NO be final, executory & demandable The Protest is a requisite for Is it acted Reinvestigation upon? NO B Taxpayer submits all relevant supporting Is it documents within 60d from the filing of granted? NO the Letter of Protest
Taxpayer has the option to:
Assessment 1. Appeal to the CTA w/n 30d from shall be Appeal to the the exp of 180d* dismissed CTA within 30d 2. Wait for the final decision of the A from the date CIR/CIR’s rep. and appeal w/n 30d of the decision from the receipt of the decision
CTA Decides Appeal to the Supreme Court End of Controversy
