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ASSESSMENT PROCESS

ISSUANCE OF LOA

Audit/Tax Investigation

NO DEFICIENCY? YES

END Inform the Taxpayer.


Issue written report.

PAY TAX NO Taxpayer disputes? YES

UPON DISPUTE

Review by Assessment
Division of RO or CIR

DISMISS. NO BASIS? YES

PRELIMINARY
ASSESSMENT

ISSUANCE OF PAN

Response from YES


NO
TAXPAYER

NO Meritorious? YES
FORMAL LETTER OF DEMAND &
FINAL ASSESSMENT NOTICE (FAN)

DISMISS
PROTEST (30 DAYS)?

NO YES

Becomes FINAL Submit supporting


and EXECUTORY. documents within 60
NO CTA APPEAL. days from filing of
COLLECTION. protest.
With or without submission of supporting documents.

CIR decision within 180 days from date of submission


of documents/filing of protest

DECISION within
NO YES
180 days?

Appeal to CTA within 30 days after NO Favorable to TP? YES


lapse of 180 days OR wait for BIR
decision (Lascona Case, 2012)

End for TP.


Sec of Finance
may review

NO File MR of the
CIRs decision? YES

Appeal to CTA within 30 NO Favorable to TP?


days from receipt of YES
adverse decision

End for TP.


NO Favorable to TP? YES Sec of Finance
may review

File MR
End for TP.
CIR may appeal NOTE: Filing of MR will not toll the
30 days period to appeal. Hence,
Favorable to TP? YES upon denial, appeal to CTA within
the remaining period.

NO

PETITION FOR
REVIEW TO SC

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