BIR Tax Authority Quiz

Letter of Authority (LOA)

• LOA is issued by the BIR to authorize tax examination of a taxpayer's accounts.
• Specifies the type of tax under review: income tax, value-added tax, withholding tax, etc.
• Typically targets one taxable year only.

Request for Documentation

• LOA includes an attachment detailing the required documents: tax reports, tax returns, accounting records.
• Revenue Officer (RO) uses these documents for examination purposes.
• Failure to submit documents results in a second request, then a final notice.
• Continued non-compliance may lead to a "Subpoena Duces Tecum," mandating document submission by a specific time.

Notice of Discrepancy (NOD)

• Findings from document checks are submitted to the Revenue District Officer (RDO) for approval.
• Taxpayers with tax deficiencies receive an NOD summarizing discrepancies.
• Discussion of Discrepancy (DOD) allows taxpayers to explain their situation and present documents.
• DODs must be conducted within 30 days of receiving the NOD.

Preliminary Assessment Notice (PAN)

• If sufficient basis for deficiency tax is found, the Commissioner issues a PAN to the taxpayer.
• Taxpayers must respond to the PAN within 15 days of receipt.

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

• FLD/FAN is issued detailing the taxpayer's deficiency tax and basis for assessment.
• Taxpayers may protest within 30 days of receiving the FLD/FAN.
• Various forms of review: request for reconsideration or reinvestigation with a 60-day submission deadline for supporting documents.
• Denied protests can be appealed to the Court of Tax Appeals (CTA) within 30 days.
• If not acted upon within 180 days, the taxpayer can appeal to the CTA or wait for final decision.

Final Decision on a Disputed Assessment (FDDA)

• The Commissioner's decision must include facts and legal basis; otherwise, it is void.