Modified Tax Assessments Procedures (RMC 102-2020 and RR 22-2020)
Highlights
Notice of Discrepancy (NOD) – The NOD aims to fully afford the taxpayer with an opportunity to present and explain his side on the discrepancy found.
Discussion of Discrepancy (DOD) – Should not extend beyond 30 days from the receipts of NOD.
It is during the Discussion of Discrepancy that the taxpayer is given the opportunity to present his side of the case and explain the discrepancy found during the investigation and submit documents to support the explanation or arguments.
The taxpayer must submit all necessary documents that supports his explanation within thirty (30) days after receipt of the Notice of Discrepancy.
If after being afforded the opportunity to present his side through the Discussion of Discrepancy, it is still found that the taxpayer is still liable for deficiency tax or taxes and the taxpayer does not address the discrepancy through payment of the deficiency taxes or the taxpayer does not agree with the findings, the investigating office, shall endorse the case to the reviewing office and approving official in the National Office or the Revenue Regional Office, for issuance of a deficiency tax assessment in the form of a Preliminary Assessment Notice within ten (10) days from the conclusion of the Discussion.