Beruflich Dokumente
Kultur Dokumente
I. Administrative Level
A. Assessment
Procedure:
Compromise Abatement
Nature
Involves a reduction of the taxpayers Involves the cancellation of the entire
liability tax liability of a taxpayer
Officer/s authorized
CIR and Regional Evaluation Board CIR
(P500,000 or less) (Sec. 7B, NIRC)
Grounds
1. Reasonable doubt as to validity of 1. The tax or any portion thereof
assessment; or appears to unjustly or excessively
2. Financial incapacity of taxpayer assessed; or
2. The administration and collection
costs involved do not justify the
collection of the amount due.
Compromise a contract whereby the parties, by
making reciprocal concessions, avoid litigation or
put an end to one already commenced. (Art.
2028, Civil Code)
Cases: Security Bank Corporation v. CIR, 22 August 2006 and Philippine National Oil
Company v. Court of Appeals, 26 April
2005
When payment of Internal revenue taxes may be
compromised (Sec. 204, NIRC)
CIVIL CASES
1. Doubtful validity
Minimum Compromise Rate: 40% of basic
tax assessed
2. Financial incapacity
Minimum Compromise Rate: 10%, 20% or
40% of basic tax assessed, depending upon
the condition of the taxpayer.
1. 25% surcharge
1. Deficiency interest
2. Delinquency interest
3. Interest on extended payment
A. Civil Action
3. No subsidiary imprisonment
Before payment
I. Administrative Level
A. Protest