Sample Protest Letter Tax Assessment Philippines Jun 2026
A protest will be considered a unless it is clearly indicated as a Request for Reinvestigation.
The FLD/FAN was issued on [date] covering taxable year [year], which is beyond the three-year prescriptive period under Section 203 of the NIRC (or ten years for false/fraudulent return under Section 222). No valid waiver of the statute of limitations was executed.
Since you did not provide a specific text, I have drafted a below followed by a critique/review of its strengths and essential legal requirements based on the National Internal Revenue Code (NIRC) and relevant BIR regulations.
Include applicable laws, rules, regulations, or jurisprudence. Be filed within 30 days.
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This is a plea for a re-evaluation of the assessment based on the and documents already submitted to the revenue officers. No new evidence is introduced. B. Request for Reinvestigation
Receiving a Formal Letter of Demand (FLD) and a Final Assessment Notice (FAN) from the Bureau of Internal Revenue (BIR) can be a stressful experience for any taxpayer in the Philippines. However, a tax assessment is not a final judgment. Philippine tax laws grant taxpayers the right to due process, allowing them to contest, dispute, and protest administrative assessments.
In support of this protest, I/We am/are attaching the following documents:
A plea for re-evaluation of the assessment based on existing records without needing to submit new evidence. This usually addresses questions of fact, law, or both. A protest will be considered a unless it
Our client, , a corporation organized and existing under Philippine laws, with principal office address at [Insert Business Address], and registered with Taxpayer Identification Number (TIN) [Insert TIN], through the undersigned counsel, respectfully files this Formal Protest by way of a Request for Reinvestigation against the Formal Letter of Demand (FLD) and Final Assessment Notice (FAN) issued by your office for the Taxable Year [Insert Year], covering alleged deficiency Income Tax, Value-Added Tax (VAT), and Expanded Withholding Tax (EWT) amounting to a total of Php [Insert Total Amount]. I. TIMELINESS OF THE PROTEST
[Provide a detailed explanation and cite the specific factual and legal basis for your disagreement.]
Below is a template that serves as a guide for drafting your formal protest.
Explicit declaration of when you received the FAN/FLD to prove you are within the 30-day window. Since you did not provide a specific text,
To prove exact land boundaries, area, and ownership.
Attention: [Name of Regional Director] Office of the Regional Director Revenue Region No. [__] – [Name of Region] Bureau of Internal Revenue
To ensure your protest letter is valid and accepted by the BIR, it must contain the following elements: Correct details of the taxpayer.
My/Our tax return for the period was correct and filed in good faith, and all taxes due have been fully paid as shown by [payment confirmation / tax credit certificate].
According to the law, a taxpayer can dispute an assessment by filing a request for reconsideration or reinvestigation within from receipt of the FAN/FLD. Reconsideration vs. Reinvestigation
This report is for general informational and educational purposes only and does not constitute legal advice. Tax laws and regulations may change. For specific cases, consult a qualified tax professional or lawyer in the Philippines.