Findings during reinvestigation or

Yes No
reconsideration: Agreed?

Pay tax through

approved BIR issues FDDA
payment form
0605

Note:
Appeal to CIR Petition to CTA
1. If the BIR issues collection
letters instead of FDDA, (Appellate Div)30 days Division (30
protest is deemed denied. days)
2. Simultaneous judicial and
admin appeals not allowed
3. INACTION: After the lapse of Post bond not
Granted to BIR Denied?
180 days, file an appeal with ACTION: more than
to cancel
CTA within 30 days if already Taxpayer should double the
assessment
lapsed, await of decision of file MR (15 days) amount of
CIR. assessment
 Reconsideration Request for reconsideration or
reinvestigation Reinvestigation

No need to submit
documents Submit docs within 60
Yes days from date of No
protest?

Reconsideration starts
Reinvestigation starts Assessment
final, executory
and demandable

BIR to issues
Collection Letters
 Final Assessment Notice (FAN) / Formal
Deman

Yes Taxpayer agreed? No

Taxpayer protested within 30 days

Pay tax through approved Yes No
from receipt of FLD/FAN?
payment form 0605

Requested for
Assessment final,
recon or rein?
executory and
demandable

BIR to issue
BIR civil remedies: garnishment , seizure,
Collection
NOTE: Levy
Letters
1. The protest may be whole or in part; Criminal remedies: File tax evasion case
2. BIR may either grant or deny the
request.
 Notice of Discrepancy

(30 days)

YES Taxpayer agreed? NO

Issue Preliminary
Pay tax through Assessment Notice (PAN)
approved Payment
Form 0605 (Reply within 15 days
from receipt)

YES Taxpayer agrees? NO

Final Assessment Notice/ Formal Letter of TP filed a reply

Demand (protest within 30 days from YES
within 15 days?
receipt)
 Audit

NO BIR need more documents? YES

Final Notice * (10

Notice of days)
Discrepancy

YES Taxpayer submits documents? NO

YES Taxpayer submits documents? SDT

Assessment based on Best BIR files criminal case NO

Evidence Obtainable (PAN)
 Issuance of E-letter of Authority with
Checklist of Requirements (10 days)

(First Notice 10-days)

YES Taxpayer submits documents? NO

Audit Starts BIR sends

Final Notice
(10 days)

YES Taxpayer submits documents? NO

YES Taxpayer submits documents? SDT