RR 22-2020
RR 22-2020
RR 22-2020
w ls srP zsz}
Date
SUBJECT: AmendingcertainSectionsofRevenueRegulationsJ,lo.{2-{999,as
and Revenue Regulations
Amended by nevenu-e-i"grlitions No. 18'210{3
in the issuance of a
No. 7-20i8, Relative to thi Due Process Requirement
Deficiency Tax Assessment
SECTION2.Amendment.-Section3ofRRNo.l2-lggg,asamendedbyRRNo'18-2013andRR
prepiration of a Notiie of Discrepancy' instead
No. 7-2018, is hereby amended by providing f-in"
provisions of Section 3 of RR No' 12-'1999' as
of a Notice of lnformal Conference. fne pErtment
amended, shall now read as follows'
,sEcTloN. 3. Due Process Requirement in the lssuance of a Deficiency Tax
Assessment. ---
![Modeofprocedureintheissuanceofadeficiencytaxassessment:
beliable for deticiency tax or
3.{.1 Notice of Discrgpancv .:.lf ?.taxpayer is found to
by a Revenue Officer, the taxpayer
taxes in the course ofSffiestigation conducted
;- froii." ot bisirepincy (Annex A). The Notice. of
shalt be informed tnr"rgh present and explain
to
Discrepancy aims to fully afford thetaxpayer with.alr opportunity
his side on the discrepancies found'
shall, among others, state in
The Revenue officer who audited the taxpayer's records
tn" initi"t report of investigation his findings of discrepancies'
RECORDS
lf 'the taxpayer disagrees with the discrepancy/discrepancies detected during the
audit/investigation, the taxpayer must present an explanation and provide documents
to support his explanation. The documents must be submitted during the discussion.
Should the taxpayer need more time to present the documents, he may submit such
documents after the discussion. The taxpayer must submit all necessary documents
that supports his explanation within thirty (30) days after receipt of the Notice of
Discrepancy.
lf after being afforded the opportunity to present his side through the Discussion of
Discrepancy, it is still found that the taxpayer is still liable for deficiency tax or taxes
and the taxpayer does not address the discrepancy through payment of the deficiency
taxes or the taxpayer does not agree with the findings, the investigating office, shall
endorse the case to the reviewing office and approving official in the National Office or
the Revenue Regional Office, for issuance of a deficiency tax assessment in the form
of a Preliminary Assessment Notice within ten (10) days from the conclusion of the
Discussion.
Failure on the part of Revenue Officers to comply with the periods indicated herein shall
be meted with penalty as provided by existing laws, rules and regulations.
xxx"
SECTION 3. Repealing Clause. - Any rules and regulations or parts thereof inconsistent with the
provisions of these Regulations are hereby repealed, amended, or modified accordingly.
SECTTON 4. Effectivity. - The provisions of these Regulations shalltake effect afierfifieen (15) days
following publication in any newspaper of general circulation.
CARLOS G. DOMI
Secretary of Flnance
$[i' 0 & ?0i0
Recommending Approval :
ffi
CAESAR R. DULAY
Commissioner of lnternal Revenue
0 36 3 6 6
ffitsEVE
i, dottuu$ N I cAT!-q
NU Ei
qLYl sl0N
l
Page 2 of 2
SEP 16 202S