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15 days 30 days
Period within CIR or
Authorized Representative
to decide FDDA Petition for Review with
CTA Division
LOA PAN Reply FLD/ Protest
NOTE: Taxpayer may file a Motion for Reconsideration with the CIR but it shall not
FAN
IF REINVESTIGATION toll the 30-day period to appeal to the CTA.
B. Recovery of Erroneously or Illegally Collected Taxes and/or Penalties (Section 229, NIRC)
2 years
File Administrative
Claim with CIR
(before Judicial
Claim)
Period to
Denial Petition for
decide
Close of the File Review with
Taxable Quarter Administrative CTA Division
when the Claim with CIR
and submit 2. If inaction:
relevant sales
complete 30 days
were made documents
Period to
Notice of Protest to decide
Local Denial by Appeal Appeal Petition
Assessment
Treasurer LT or to MTC to RTC for
Lapse of Review
60 days to the
CTA en
banc
2. Refund
2 years
1. If ≤ P300,000 (or ≤ P400,000 for Metro Manila)
Period to
Pay with Protest to decide Denial by Appeal Denial Appeal Adverse Petition
Protest Local LT or to LBAA by LBAA to the Decision of for
Treasurer Lapse of or Lapse CBAA the CBAA Review to
the CTA
60 days of 120-
en banc
days
b. Illegal Assessment
15 days 30 days
2. Refund
2 years 60 days
A. Assessments
1. If protest is sustained
15 days 30 days
The COC shall make the appropriate order and the entry reassessed, if necessary.
B. Refund
1. If the claim and application is for refund of duties.
12 months If the claim is denied If denied by the COC
Note: The Bureau of Customs shall cause the refund of internal revenue taxes after issuance of a certification from the CIR
granting claim for refund, whether wholly or partially.
C. Forfeiture
30 days or 10
5 days If no decision rendered within the said period or when a decision adverse to
days if perishable
government is rendered by the COC involving goods with FOB or FCA value of
goods
P10,000,000.00
Period 5 days
Adverse Elevate Receipt of for COC
decision Records records by to decide
of District to CoC CoC NOTE: The decision of the SOF
Collector whether or not a decision was
COC Elevate rendered by the COC within 30 days,
records to or within 10 days in the case of
SoF perishable goods, from receipt of the
records, shall be final upon the
Bureau.
3. If the importer is aggrieved by the decision of the Secretary of Finance on automatic review
30 days
2. If in the exercise of the CIR’s power to interpret tax laws (Revenue Memorandum Circulars and Revenue Memorandum Orders)