Sample Protest Letter Tax Assessment Philippines May 2026

The alleged deficiency for 2022 is based on an LOA issued on [date]. However, our 2022 Annual ITR was filed on [April 15, 2023]. The three-year prescriptive period expired on [April 15, 2026]. The FAN was issued on [date, e.g., May 20, 2026], which is beyond the prescriptive period . Hence, the right to assess has prescribed.

This protest is filed within as required under Section 228 of the National Internal Revenue Code (NIRC) of 1997, as amended. sample protest letter tax assessment philippines

The assessment is on the following specific grounds: The alleged deficiency for 2022 is based on

| Item | BIR Assessment | Taxpayer’s Corrected | Difference | |------|----------------|----------------------|------------| | Gross Sales | P 10,000,000 | P 10,000,000 | – | | Less: COGS | P 6,000,000 | P 7,500,000 | P 1,500,000 | | Net Income | P 4,000,000 | P 2,500,000 | (P 1,500,000) | | Income Tax Due (25%) | P 1,000,000 | P 625,000 | (P 375,000) | | Less: Credits/Withheld | P 500,000 | P 500,000 | – | | | P 500,000 | P 125,000 | (P 375,000) | The FAN was issued on [date, e

Dear Sir/Madam:

The BIR disallowed input VAT in the amount of P [amount] on purchases from suppliers listed as “non-compliant” in the BIR’s system. Attached as Annex “A” are (1) official receipts, (2) sworn declarations from the suppliers confirming their VAT registration during the transaction period, and (3) BIR Form 2303 of said suppliers. The disallowance is without factual basis.

The alleged deficiency for 2022 is based on an LOA issued on [date]. However, our 2022 Annual ITR was filed on [April 15, 2023]. The three-year prescriptive period expired on [April 15, 2026]. The FAN was issued on [date, e.g., May 20, 2026], which is beyond the prescriptive period . Hence, the right to assess has prescribed.

This protest is filed within as required under Section 228 of the National Internal Revenue Code (NIRC) of 1997, as amended.

The assessment is on the following specific grounds:

| Item | BIR Assessment | Taxpayer’s Corrected | Difference | |------|----------------|----------------------|------------| | Gross Sales | P 10,000,000 | P 10,000,000 | – | | Less: COGS | P 6,000,000 | P 7,500,000 | P 1,500,000 | | Net Income | P 4,000,000 | P 2,500,000 | (P 1,500,000) | | Income Tax Due (25%) | P 1,000,000 | P 625,000 | (P 375,000) | | Less: Credits/Withheld | P 500,000 | P 500,000 | – | | | P 500,000 | P 125,000 | (P 375,000) |

Dear Sir/Madam:

The BIR disallowed input VAT in the amount of P [amount] on purchases from suppliers listed as “non-compliant” in the BIR’s system. Attached as Annex “A” are (1) official receipts, (2) sworn declarations from the suppliers confirming their VAT registration during the transaction period, and (3) BIR Form 2303 of said suppliers. The disallowance is without factual basis.