Updated 10 Mar 2013

PM REYES NOTES ON TAXATION II:

CUSTOMS & DUTIES
1. Organization, Powers and Jurisdiction The BOC’s duties, powers, and jurisdiction include:1

(Read Section 601-609, Tariff and Customs 1. The assessment and collection of the lawful
Code) revenues from imported articles and all other
dues, fees, charges, fines, and penalties
accruing under the TCC
Q1.Which body is responsible for the
2. The prevention and suppression of
enforcement of the Tariff and Customs smuggling and other customs frauds
Code (TCC)? 3. The supervision and control over the
entrance and clearance of vessels and
There are actually two bodies. The 1978 Tariff and aircraft engaged in foreign commerce
Customs Code (TCC) is divided into two parts: (1) the 4. The enforcement of the TCC
Tariff Law (Sections 100-519) and; (2) the Customs 5. The supervision and control over the
Law (Sections 601-3705). The Tariff Commission is handling of foreign mails arriving in the
the governing body in relation to the Tariff Law. The Philippines
Bureau of Customs (BoC) implements the Customs 6. Supervise and control all import and export
Law. cargoes, landed or stored in piers, airports,
terminal facilities for the protection of
Q1.1. Briefly discuss the organization, government revenue
functions, and jurisdiction of the 7. Exercise exclusive original jurisdiction over
Tariff Commission seizure and forfeiture cases

The Tariff Commission (TC) is a collegial body Q1.2.1. Can the regular courts
consisting of a Chairman and two commissioners. assume cognizance and pass
upon the validity ore
The TC is charged with the implementation and has regularity of seizure and
primary jurisdiction of the Tariff-related provisions of
forfeiture proceedings by the
the TCC, such as:
BoC and enjoin or otherwise
1. Section 301 (Anti-Dumping Investigations) interfere with such
2. Section 302 (Countervailing Investigations) proceedings?
3. Section 401 (Flexible Clause)
4. Section 402 (Promotion of Foreign Trade) No. As held in SUBIC BAY METROPOLITAN AUTHORITY
5. Section 505 (Trade Monitoring) V. RODRIGUEZ [APRIL 23, 2010], the Collector of
6. Section 506 (Assistance to the President and Customs has exclusive jurisdiction over seizure and
Congress on evaluation of tariff and tariff- forfeiture proceedings and the regular courts cannot
related matters) interfere with his exercise thereof or enjoin or
7. Section 1313A (Tariff Commodity interfere with it. The regular courts are precluded
Classification) from assuming cognizance over such matters even
8. R.A. 8800 (Safeguard Measures Act) through petitions for certiorari, prohibition, or
mandamus.
Q1.2. Briefly discuss the organization,
functions, and jurisdiction of BoC The RTC must defer to the exclusive original
jurisdiction of the BOC in such proceedings. This is
known as the doctrine of primary jurisdiction.
The BOC consists of the Commissioner of Customs
and five Deputy Commissioners.
1
Those underlined are the notable ones.

PM REYES NOTES ON TAXATION II: CUSTOMS AND DUTIES

BY PIERRE M ARTIN DE LEON REYES

This reviewer is a compilation of personal notes in Taxation Two and notes and lectures from Atty. Gruba and Atty. Montero. References have
also been made to the following books: DE LEON & DE LEON, J R. THE FUNDAMENTALS OF TAXATION (2012); DE LEON & DE LEON, JR.
COMPREHENSIVE REVIEW OF TAXATION (2010); VITUG & ACOSTA. TAX LAW AND JURISPRUDENCE (2006); DOMONDON, TAXATION VOLUME II: INCOME
TAX (2009); CO-UNTIAN, JR. TAX DIGEST (2009); MAMALATEO , REVIEWER ON TAXATION (2008). This reviewer is best used with SACDALAN-
CASASOLA, NIRC AND OTHER LAWS (2012).

Possessors are granted the right to reproduce and distribute this reviewer as well as the right to convert the work to any medium for the
purpose of preservation and/or continued distribution provided that the author’s name remains clearly associated with the work and that no
alterations of the form and content are made.

PM REYES NOTES ON TAXATION II:
CUSTOMS & DUTIES
Q1.2.2. When does the BoC acquire
exclusive jurisdiction over
imported goods for the
purpose of enforcing
customs laws?
From the moment imported goods are actually in the
possession or control of the Customs authorities,
even if no warrant for seizure or detention had
previously been issued by the Collector of Customs
in connection with the seizure and forfeiture
proceedings. (see SUBIC BAY METROPOLITAN
AUTHORITY V. RODRIGUEZ [APRIL 23, 2010])
2. Articles subject to Duty
(Read Section 1201-1202, TCC)
Meaning of Importation
Q2.When does importation begin and when
is deemed to have terminated?
Importation begins when the goods enter the PH
jurisdiction with intention to unlade therein. It
terminates upon the payment of taxes or legal permit
to withdraw has been granted.
Q2.1. When are imported articles
deemed to have “entered” the PH
for consumption?
Imported articles shall be deemed "entered" in the
Philippines for consumption when the specified entry
form is properly filed and accepted, together with any
related documents required by the provisions of this
Code and/or regulations to be filed with such form at
the time of entry, at the port or station by the customs
official designated to receive such entry papers and
any duties, taxes, fees and/or other lawful charges
required to be paid at the time of making such entry
have been paid or secured to be paid with the
customs official designated to receive such monies,
provided that the article has previously arrived within
the limits of the port of entry. (see SECTION 205, TCC)
Q2.2. When are imported articles
deemed have been “withdrawn”
from the warehouse in the PH for
consumption?
PIERRE MARTIN DE LEON REYES
Updated 10 Mar 2013
Imported articles shall be deemed "withdrawn" from
the warehouse in the Philippines for consumption
when the specified form is properly filed and
accepted, together with any related documents
required by any provisions of this Code and/or
regulations to be filed with such form at the time of
withdrawal, by the customs official designated to
receive the withdrawal entry and any duties, taxes,
fees and/or other lawful charges required to be paid
at the time of withdrawal have been deposited with
the customs official designated to receive such
payment.” (see SECTION 205, TCC)
Classes of Importation
Q3.What is the rule on the imposition of
duties on imported articles?
General Rule: All imported articles shall be subject
to duty even though previously exported from the
Philippines
Exception: Such articles will not be subject to duty if
exempted by the TCC or other laws.
Q4.What are the classes of importation under
the TCC?
1. Dutiable Importation (Section 100, TCC)
2. Prohibited Importations (Section 101 and
1207, TCC)
3. Conditionally-Free Importations (Section 105,
TCC)
4. Drawbacks (Section 106, TCC)
Q4.1. What are dutiable importations?
They refer to those imported articles subject to duty
and not otherwise exempted by the TCC or other
special laws.
Q4.2. What are prohibited importations?
They refer to those articles that are cannot be
imported into the PH because they are contrary to
policy, morals, laws, etc.
Examples include:
1. Dynamite, gunpowder, ammunition and
explosives, other weapons (except when
authorized by law)
2

PM REYES NOTES ON TAXATION II:
CUSTOMS & DUTIES
2. Written or printed articles advocating or
inciting treason, rebellion, or insurrection
3. Written or printed articles, etc of an obscene
or immoral character
4. Articles, instruments, drugs and substances
designed for unlawful abortion
5. Devices used in gambling or the distribution
of money, cigarettes, or other articles when
such distribution is dependent on chance
6. Lottery and sweepstakes tickets (Except
those authorized)
7. Any article manufactured in gold, silver or
other precious metals when there is no
indication of the actual fineness of quality
8. Adulterated or misbranded articles of food
and drugs
9. Marijuana, opium and other narcotics
10. Opium pipes and parts thereof
11. All other articles and parts prohibited by law
or rules and regulations
Q4.3. What are conditionally-free
importations?
They refer to those articles which are allowed to be
imported into the PH but subject to conditions.
Examples include:
1. Articles for repair, re-conditioning to be re-
exported within 6 months (requires a bond)
2. Personal effects for balikbayans excluding
cars, and must not be commercial quantity
and no exceeding P2,000 (can be brought in
90 days after arrival)
3. Articles to be donated to relief organizations
(must be certified by DSWD, DepEd)
4. Samples not for commercial sales, including
medicines (but must not be available in PH)
5. Economical, technical, vocational, scientific,
philosophical, historical, cultural
books/publications and bibles
Q4.4. What are drawbacks?
They refer to refunds or tax credits of duties paid on
goods that are being exported or used in the
production of manufactured exports2
Examples include:
2
Section 106(e), TCC provides that “Claims for refund or tax credit
eligible for such benefits shall be paid or granted by the Bureau of
Customs to claimants within sixty (60) days.”
PIERRE MARTIN DE LEON REYES
Updated 10 Mar 2013
1. Fuel used for propulsion of vessels engaged
in trade with foreign countries or coastwise
trade
2. Petroleum Oils or Oils obtained from
bituminous minerals, crude eventually used
for generation of electric power and
manufacture of city gas
3. On certain articles made from imported
articles subject to certain conditions.
3. Rates of Duty
General Rules
(Read Section 104, TCC)
Q5.What is the rule on rates of import duty?
General Rule: There shall be levied, collected and
paid upon all imported articles the rates of duty. The
maximum rate shall not exceed 100% ad valorem.
The rates apply to all products imported from foreign
countries.
Exception: An additional 100% across-the-board
duty is imposable for imports from foreign countries
who discriminate against Philippine exports.
Q6.What are the two elements in determining
whether duties are to be paid on imported
articles?
1. The type of good (to determine the duty
rate)3
2. The dutiable value (make reference to the
basis of duty)
Basis of Duty
(Read Section 201-205 & 1313, TCC)
Q7.What are the methods of determining
dutiable values?
The methods of determining the dutiable value are as
follows (by order of preference):
3
Note that the TCC follows the Harmonized Commodity
Description and Coding System (HS). Under the Harmonized
System, goods are classified according to sections, chapters,
headings and subheadings. Each classification is provided a rate
of import duty.
3

PM REYES NOTES ON TAXATION II:
CUSTOMS & DUTIES
1. Transaction value – an ad valorem rate of
duty equivalent to the price actually paid or
payable for the goods when sold for export to
the Philippines, as adjusted;
2. Transaction value of identical goods – the
transaction value of identical goods sold for
export to the Philippines and exported at or
about the same time as the goods being
valued; “identical goods” shall mean goods
which are the same in all respects, including
physical characteristics, quality and
reputation, discounting minor differences in
appearances;
3. Transaction value of similar goods – the
transaction value of similar goods sold for
export to the Philippines and exported at or
about the same time as the goods being
valued; “similar goods” shall mean goods
which, although not alike in all respects, have
like characteristics and like component
materials which enable them to perform the
same functions and to be commercially
interchangeable;
4. Deductive value4 – an amount based on the
unit price at which the imported gods or
identical or similar imported goods are sold in
the Philippines, in the same condition as
when imported, in the greatest aggregate
quantity, at or about the time of importation of
the goods being valued, to persons not
related to the persons from whom they buy
such goods, as adjusted;
5. Computed value – the aggregate value of
the cost or value of materials and fabrication
or other processing employed in producing
the imported goods, amount for profit
andNgeneral expenses, freight, insurance
fees and other transportation expenses for
the importation of the goods, among others;
and
6. Fallback value – an amount determined by
using other reasonable means and on the
basis of data available in the Philippines.
4
Methods four and five may be reversed.
PIERRE MARTIN DE LEON REYES
Updated 10 Mar 2013
Q7.1. Define transaction value
It is the price actually paid/payable when exported to
PH adjusted by adding the following:
1. Commissions, cost of containers, packing
cost, cost of tools, engineering, artwork if
supplied free of charge, royalties
2. Value of subsequent resale accruing to the
seller
3. Cost of transport & loading/unloading
charges from port of exportation to port of
entry in PH (costs within PH already
excluded)
4. Insurance.
Q7.2. When is transaction value (method
one) not used?
1. Buyer imposes restrictions on sale or use of
goods (except if imposed by law,
geographical limits, not affect value of goods)
2. Sale is subject to some
condition/consideration which cannot be
valued
3. Part of subsequent resale accrues to seller
and amount undeterminable
4. Buyer and seller are related
a. business partners
b. holds 5% equity
c. common control
d. relatives up to 4th degree
Q8.What are the special duties under the
TCC?
1. Anti-Dumping (Section 301, TCC)
2. Countervailing (Section 302, TCC)
3. Marking (Section 303, TCC)
4. Discriminatory (section 304, TCC)
Q8.1. What is an anti-dumping duty?
It is a special duty imposed on the importation of a
product, commodity or article of commerce into the
Philippines at less than its normal value when
destined for domestic consumption in the exporting
country which is the difference between the export
price and the normal value of such product,
commodity or article.
4

PM REYES NOTES ON TAXATION II:
CUSTOMS & DUTIES
Q8.1.1. What must be alleged in an
anti-dumping action?
The action is initiated by filing a complaint alleging
the following:
1. Dumping
2. Injury
3. Causal link between the dumped imports and
the alleged injury
Q8.2. What is a countervailing duty?
It is a special duty imposed on the importation of a
product, commodity or article of commerce into the
Philippines when the same is granted directly or
indirectly by the government in the country of origin
or exportation any kind or form of specific subsidy
upon the production, manufacture or exportation of
such product, commodity or article, and the
importation of such subsidized product, commodity or
article has caused or threatens to cause material
injury to a domestic industry or has materially
retarded the growth or prevents the establishment of
a domestic industry as determined by the Tariff
Commission.
Q8.2.1. Differentiate a bounty and a
subsidy.
Bounty is the cash award paid to an exporter while
subsidy refers to fiscal incentives, not in the form of
cash award, to encourage manufacturers or
exporters. The duty is equal to the ascertained or
estimated amount of the bounty or subsidy.
Q8.1.2. What must be alleged in a
countervailing action?
The action is initiated by filing a complaint alleging
the following:
1. Financial contribution
2. Benefit conferred
3. The subsidy must be specific5
Q8.3. What is a marking duty?
Every article of foreign origin imported into the
Philippines, as a general rule, must be marked in any
official language of the Philippines and in a
5
This element is not required if the subsidy is an export subsidy.
PIERRE MARTIN DE LEON REYES
Updated 10 Mar 2013
conspicuous place as legibly, indelibly and
permanently as the nature of the article or container
will permit in such manner as to indicate to an
ultimate purchaser in the Philippines the name of the
country of origin of such article; failure to comply with
the requirements by law shall subject to relevant
article to a marking duty.
This is subject to certain exceptions such as:
1. If goods cannot be marked without injury to
the article
2. Crude substance
3. Importer necessarily knows origin
Q8.4. What is a discriminatory duty?
It is a special duty that may be imposed by the
President of the Philippines when he finds that the
public interest will be served thereby, in case a
product, commodity or article of commerce is
imported in a vessel of any of a foreign country and
the President finds as a fact that such country
discriminates against the commerce of the
Philippines in such manner as to place the commerce
of the Philippines at a disadvantage compared with
the commerce of any foreign country.
Flexible Tariff Rates
(Read Section 401, TCC)
Q9.What is the flexible clause?
SECTION 401(A) of the TCC provides that in the
interest of national economy, general welfare and/or
national security and subject to certain prescribed
limitations, the President, upon the recommendation
of the NEDA, is empowered to: (1) increase, reduce
or remove existing protective rates of import duty; (2)
to establish import quota or to ban imports of any
commodity, as may be necessary; and (3) to impose
an additional duty on all imports not exceeding 10%
ad valorem whenever necessary.
4. Imposition of Duties
Persons liable
(Read Section 1203-1205, TCC)
Q10. Who are the persons liable for duties?
1. The consignee, the holder of a bill of lading
duly indorsed by the consignee, or the
consignor if consigned to order
5

PM REYES NOTES ON TAXATION II:
CUSTOMS & DUTIES
2. As a general rule, the government for
importations for its own use of that of its
subordinate branches, instrumentalities,
corporations, agencies or instrumentalities
(except as otherwise provided in Section
105; conditionally free importations)
Declaration
(Read Section 1301-1307, TCC)
Q11. Who are the persons authorized to
make an import entry (to enter the
imported articles in the customhouse of
the port of entry)?
1. The importer being the holder of the bill of
lading
2. Duly licensed customs broker acting under
authority of the holder of the bill of lading
3. Person duly empowered to act as agent of
the holder of the bill of lading
Q12. What must the declaration of import
entry contain?
1. It must contain statements of substance as
follows:
a. The full account of the value or price
of said articles including subject of
the entry
b. A just and faithful account of the
value or price of said articles
c. All the invoice and bills of lading are
the only ones in existence
d. The entries, invoices and bill of
lading, and the declaration thereon
are genuine and true and made by
the person by whom the same
purports to have been made.
2. It must be signed by the importer, consignee,
holder of the bill, the manager in the case of
a corporation, or by a licensed customs
broker
3. It shall contain the names of the importing
vessel or aircraft, port of departure and date
of arrival, the number and marks of
packages, or the quantity, the nature and
correct commodity description
4. The commodity description must be in
sufficient detail to be identified both for HS
and statistical purposes
PIERRE MARTIN DE LEON REYES
Updated 10 Mar 2013
Examination, Appraisal and
Classification
(Read Section 1401-1408, TCC)
Q13. What are the duties of a customs officer
in relation to the examination,
classification and appraisal of imported
articles?
The customs officer tasked to examine, appraise, and
classify imported articles shall:
1. Determine whether the packages designated
for examination and their contents are in
accordance with the customs entry
declaration
2. make a return to indicate whether the articles
have truly and correctly been declared in the
entry
3. Submit samples to the laboratory for analysis
when feasible andn necessary
4. Determine the unit of quantity in which the
articles are usually bought and sold
Q14. In what instances shall imported
articles be subject to regular physical
examination?
1. The government surveyor’s seal on the
container has been tampered with or the
container shows signs of having been
opened
2. Container is leaking or damaged
3. The number, weight and nature of packages
indicated in the customs entry declaration
differ from the manifest
4. The shipment is covered by alert or hold
orders
5. The importer disagrees with the findings
contained in the government surveyor’s
report
6. The articles are imported through air freight
where the Commissioner or Collector has
knowledge that there is variance between the
declared and true quantity, measurement,
weight and tariff classification
6

PM REYES NOTES ON TAXATION II:
CUSTOMS & DUTIES
Liquidation
(Read Section 1601-1603, TCC)
Q15. What is liquidation in relation to the
TCC?
Liquidation means the final computation or
ascertainment of the duties to be imposed on the
imported articles.
5. Remedies of the Government
Q16. Who has jurisdiction over importation
of articles and over articles of
prohibited importation?
The Collector of Customs (see SECTION 1206-1207,
TCC)
Extrajudicial
Q17. What are the extrajudicial (or
administrative remedies) available to
the government?
1. Enforcement of tax lien (Section 1508, TCC)
2. Seizure and forfeiture (Section 2201-2212,
2301-2317, 2530-2536, TCC)
Enforcement of Tax Lien
Q17.1. Discuss the authority of the
Collector to hold the delivery or
release of imported articles.
The Collector shall hold the delivery of any article
imported or consigned to an importer whenever such
importer has an outstanding and demandable
account with the BoC. If subsequently authorized by
the Commissioner and upon notice, the Collector
may sell such importation or a portion thereof to
cover the outstanding account of the importer.
Search, Seizure and Arrest
Q17.2. Discuss the administrative and
judicial proceedings in customs
seizure and forfeitures.
PIERRE MARTIN DE LEON REYES
Updated 10 Mar 2013
If the owner or imported is aggrieved by the decision
of the Collector:
1. Collector issues warrant for detention of
property (if owner or importer desires to
secure release of property for legitimate use,
Collector may surrender subject property
upon filing of sufficient bond)
2. Collector immediately reports seizure to COC
and Chairman of COA
3. Collector gives owner or importer or his
agent written notice of seizure and
opportunity to be heard
4. Collector causes preparation of list and
particular description of property seized, as
well as appraisal and classification of the
same
5. Collector, after hearing and in writing, makes
a declaration of forfeiture or fixes amount of
fine or takes such action as may be proper
6. Owner or importer is aggrieved
7. Appeal to Collector within 15 days after
notification in writing by the Collector of his
action or decision
8. Appeal to CTA Division within 30 days from
notice
9. Appeal to CTA En Banc
10. Appeal to SC by certiorari within 15 days
If the government is aggrieved by the decision of the
Collector:
1. Collector issues warrant for detention of
property (if owner or importer desires to
secure release of property for legitimate use,
Collector may surrender subject property
upon filing of sufficient bond)
2. Collector immediately reports seizure to COC
and Chairman of COA
3. Collector gives owner or importer or his
agent written notice of seizure and
opportunity to be heard
4. Collector causes preparation of list and
particular description of property seized, as
well as appraisal and classification of the
same
5. Collector, after hearing and in writing, makes
a declaration of forfeiture or fixes amount of
fine or takes such action as may be proper
6. Government is aggrieved
7. Automatic review by COC
8. Automatic review by DOF Secretary
9. If owner or importer is aggrieved by decision
of COC or DOF Secretary
7

PM REYES NOTES ON TAXATION II:
CUSTOMS & DUTIES
10. Appeal to CTA Division within 30 days from
notice
11. Appeal to CTA En Banc
12. Appeal to SC by certiorari within 15 days
Judicial
Post-Entry Audit
(Sections 3514-3518, TCC as amended by RA
9135)
Q18. What is a post-entry audit?
The importers/customs brokers shall allow any
customs officer authorized by the BoC to enter during
office hours any premises or place where the records
of importations of an importer are kept to conduct
audit examination, inspection, verification, and/or
investigation of those records
Surcharges. Fines and Forfeitures
(Read Sections 2501-2529, 3601-3612, TCC)
Q19. What is the effect of failure to pay
liquidated duties, taxes and other
charges?
Failure to pay within 10 days after the notice of
liquidation is publicly posted in the customhouse shall
lead to the imposition of a 10% surcharge (of the total
amount or balance upon liquidation)
If the delinquency is for more than a year, the
surcharge shall be increased to 25%
Q20. What are the penalties under the TCC?
1. Negligence – when a deficiency results from
an offender’s failure to exercise reasonable
care and competence to ensure that a
statement made is correct, it shall be
determined to be negligent = fine equivalent
to ½ to 2 times the revenue loss
2. Gross Negligence – when a deficiency
results from an act or acts of omission or
commission done with actual knowledge or
wanton disregard for the relevant facts, it
shall be determined to be grossly negligent =
fine equivalent to 2 ½ to 5 times the revenue
loss
PIERRE MARTIN DE LEON REYES
Updated 10 Mar 2013
3. Fraud – when the material false statement or
act in connection with the transaction was
committed or omitted knowingly, voluntarily,
and intentionally as established by clear and
convincing evidence, it shall be determined
to be fraudulent = fine of 5 to 8 times revenue
loss and imprisonment of 2 to 8 years.
6. Remedies of the Taxpayer
Q21. What are the remedies of the taxpayer
under the TCC?
1. Abatement & Refund (Sections 1701-1708,
TCC)
2. Protest (Sections 2308-2317, TCC)
3. Abandonment (Sections 1801-1802, TCC)
Q21.1. What are the instances where the
Collector may abate or refund the
amount of duties accruing or paid
by the importer?
1. Damage incurred during voyage
2. Missing package
3. Deficiency in contents of packages
4. Articles lost or destroyed after arrival
5. Dead or injured animals
6. Refund of Excess payments (made due to
manifest clerical errors)
Q21.2. When is an article deemed
abandoned?
1. Importer expressly signifies in writing to the
Collector his intention to abandon
2. When the importer fails to file an entry within
30 days (not extendible) from the date of
discharge of the last package or having filed
such entry, fails to claim the imported articles
within 15 days (not extendible) from the date
of posting of the notice to claim such
importation
Q21.2.1. What is the effect of
abandonment?
Any person who abandons an article shall be
deemed to have renounced all his interests and
property rights therein.
8
 Updated 10 Mar 2013
PM REYES NOTES ON TAXATION II:
CUSTOMS & DUTIES
An abandoned article shall ipso facto be deemed the
property of the Government.

Q21.3. Discuss the procedure for

customs protest.

If the owner or imported is aggrieved by the decision

of the Collector:

1. Protest to the Collector within 15 days

2. If aggrieved by the decision or action of the
collector upon protest, appeal to the
Commissioner within 15 days after
notification in writing by the Collector of his
action or decision
3. Appeal to CTA Division within 30 days from
notice
4. Appeal to CTA En Banc
5. Appeal to SC by certiorari within 15 days

If the government is aggrieved by the decision of the

Collector:

1. Protest to the Collector within 15 days

2. If aggrieved by the decision or action of the
collector upon protest, appeal to the
Commissioner within 15 days after
notification in writing by the Collector of his
action or decision
3. Automatic review by COC
4. Automatic review by DOF Secretary
5. If owner or importer is aggrieved by decision
of COC or DOF Secretary
6. Appeal to CTA Division within 30 days from
notice
7. Appeal to CTA En Banc
8. Appeal to SC by certiorari within 15 days

Q21.3.1. What is the form and scope

of the protest?

Every protest shall point out the particular decision or

ruling of the Collector to which exception is taken or
objection made, and shall indicate with reasonable
precision the particular ground or grounds upon
which the protesting party bases his claim for relief.

The scope of a protest shall be limited to the subject

6
matter of a single adjustment or other independent
transaction, but any number of issues may be raised
in a protest with reference to the particular item or
items constituting the subject matter of the protest.
6
A “single adjustment” refers to the entire content of one
liquidation.

PIERRE MARTIN DE LEON REYES 9