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Motion for Reconsideration of FDDA

- BIR Tax Assessment


- VAT Assessment

BIR Admin procedures

- LOA is the starting point of the audit


- Checklist and submit documents, the negotiation process with the BIR begins
- After the negotiations, BIR will send 1st, 2nd and final notice to comply with the LOA, or else the
BIR will issue an subpoena deuces tecum which results in a criminal case.
- Examiner will issue a preliminary finding
- Notice of Discrepancy
o Reply within 5 days
- Examiners have 30 days to examine again or renegotiate
- If nothing happens, a PAN is issued wherein taxpayer has 15 days to reply
- Upon FAN, we have 30 days to file Recon for reinvestigation
o In a motion for reinvestigation, we have 60 days to submit additional supporting
documents
- Upon MR, 180 days for the examiner to decide, the FDDA will be issued. MR to CIR or admin.
Appeal within 30 days.

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