CIR / Authorized Representative issues the PAN

T/P does not respond T/P responds beyond 15 days T/P responds within 15 days

T/P disagrees with

T/P agrees with findings
findings

CIR / Authorized Representative issues the FLD / FAN Assessment becomes final

T/P does not T/P protests T/P responds within 15

protest beyond 30 days days

Assessment becomes final

Petition for Reinvestigation Petition for Reconsideration

T/P does not submit all T/P submits docs T/P submits docs within
relevant docs beyond 60 days 60 days

Assessment becomes final

Denied by CIR's Protest or Administrative Appeal is denied

representative
File Protest to
Appeal to the Court
Commissioner through
of Tax Appeals within
Request for Reconsideration
30 days from receipt
within 30 days from
of decision
receipt of decision
Appeals within 30 days after
the expiration of the 180-day
Denied by CIR No action from CIR
within 180 days from
filing
Refer to above Refer to above
No Action from CIR within 180 days from
filing if Protest of Reconsideration OR
180 days from submission of complete
documents if Protest of Reinvestigation
Await the final
Appeal to the Court of Tax
decision of CIR's
representative on
the disputed
period
assessment
T/P agrees with decision
Assessment becomes final
Appeal to the Court of Tax Appeals within 30
days from receipt of decision
by CIR
No Action from CIR within 180 days from filing if
Protest of Reconsideration OR 180 days from
submission of complete documents if Protest of
No action from T/P Reinvestigation
Appeal to the Court
of Tax Appeals within
30 days from receipt
Assessment becomes final
of decision
Appeal to the Court of Tax
Appeals within 30 days after Await the CIR's final decision on the
the expiration of the 180-day disputed assessment
period
T/P disagrees with decision
T/P agrees with decision
T/P disagrees with decision
Assessment becomes final

Appeal to the Court of Tax Appeals

within 30 days from receipt of decision
 CIR / Authorized Representative issues the PAN

T/P does not T/P responds T/P responds within 15

respond beyond 15 days days

CIR / Authorized CIR / Authorized

Representative Representative
issues FLD/FAN issues FLD/FAN
 PAN

T/P responds within 15

days