Taxpayer’s Submission of

Tax Returns

BIR issues Letter of

Authority

If there is discrepancy, BIR If there is no discrepancy,

sends Notice of Informal action will NOT be
Conference pursued.

Taxpayer has 15 days to

respond from receipt of
notice

If the taxpayer’s response If the taxpayer’s response

is not acceptable or there is acceptable, the action
is no response, it shall be will NOT be pursued.
endorsed to Assessment
Division

BIR issues preliminary

assessment notice (PAN)

Taxpayer has 15 days to

respond from receipt of
PAN

If the taxpayer’s response If the taxpayer’s response

is not acceptable or there is acceptable, the case is
is no response, BIR shall dismissed.
issue Final Assessment
Notice (FAN) & Letter of
Demand
 Taxpayer has 30 days to
Taxpayer failed to timely
protest from receipt of FAN
protest, the assessment
(request for reconsideration
becomes final, executory
or reinvestigation)
and demandable.

Taxpayer protested within

30 days from receipt of
FAN.

Taxpayer has 60 days from

protest within which to
submit supporting
documents

BIR Commissioner has 180 If the taxpayer’s response

days from receipt of is acceptable, the case is
supporting documents dismissed
within which to act on the
protest

BIR Commissioner did not Taxpayer has 30 days from

act on the receipt of BIR’s denial
protest/unacted within which to appeal
claim/lapse of 180 day before the CTA Division
period

Taxpayer has 30 days from

receipt of BIR’s denial
within which to appeal
before the CTA Division
 Taxpayermay file Petition
for Review before the CTA
Division

Petition dismissed. Petition granted.

Assessment null and void.

Taxpayer may file M/R

within 15 days from
receipt of decision

Motion denied. Motion granted.

Assessment null and void.

Taxpayer may file Petition

for Review before the CTA
En Banc

Petition dismissed. Petition granted.

Assessment null and void.

Taxpayer may file M/R

within 15 days from
receipt of decision

Motion denied. Motion granted.

Assessment null and void.

Taxpayer may file Petition

for Review before the SC