Administrative protest of assessment

under Rev. Regs. No. 12-99

as amended by Rev. Regs. No. 18-13
Taxpayer is found to be
liable for deficiency taxes

Taxpayer does not respond w/in 15 days from

receipt of PAN taxpayer considered in default

BIR issues preliminary

assessment notice (PAN)

Taxpayer responds w/in 15

days from receipt of PAN

BIR issues formal letter of demand/final assessment notice (FLD/FAN) w/in 15

days from lapse of period to respond to PAN or from filing of response

Taxpayer does not protest FLD/FAN

w/in 30 days from receipt
Taxpayer protest FLD/FAN w/in
30 days from receipt

Assessment becomes final,

executory, and demandable

Taxpayer files a Request for

Reinvestigation

Taxpayer files a Request for

Reconsideration

Taxpayer submits supporting

documents w/in 60 days from filing of
protest

Taxpayer fails to submit supporting

documents w/in 60 days from filing of
protest

180 days from filing of

Request for Reconsideration
has elapsed

180 days from filing of

Request for Reconsideration
has NOT yet elapsed

180 days from submission of

supporting documents (or
from filing of RFR if no
supporting docs submitted)
has NOT YET elapsed

Wait for Final Decision

on Disputed Assessment
(FDDA)

180 days from submission of

supporting documents
documents (or from filing of
RFR if no supporting docs
submitted) has elapsed

Wait for Final Decision

on Disputed Assessment
(FDDA)

BIR issues FDDA

Protest
denied by CIR

Protest denied by
CIRs representative

Taxpayer has 30 days to

elevate protest to CIR

Taxpayer has 30 days to appeal

to Court of Tax Appeals