TRAIN Briefing – Power & Authority of the CIR

VER 1.0 – January 2018

ESTATE
TAX
Estate Tax
NIRC NIRC TRAIN
Provision
Section 84 The Estate Tax rate is based on graduated schedule. The Estate Tax rate is fixed at
Rates of NET ESTATE TAX 6% based on the value of the
Estate Tax net estate.
Not over ₱200,000 Exempt
Over ₱200,000 but not 5% of the excess over
over ₱500,000 ₱200,000
Over ₱500,000 but not ₱15,000 + 8% of the
over ₱2M excess over ₱500,000
Over ₱2M but not over ₱135,000 + 11% of the
₱5M excess over ₱2M
Over ₱5M but not over ₱465,000 + 15% of the
P10M excess over ₱5M
Over ₱10M ₱1,215,000 + 20% of the
excess over ₱10M
Estate Tax
NIRC Provision NIRC TRAIN
Section 86 (A) The value of the net estate of a The following are the allowable
Allowable resident or citizen is determined by deductions from the gross estate of a
deductions from the deducting the following from the resident or citizen:
gross estate of a gross estate: 1. Standard deduction of
citizen/resident 1. Standard deduction of ₱5,000,000;
₱1,000,000; 2. Claims against the estate;
2. Expenses, losses, 3. Claims against insolvent persons;
indebtedness, and taxes 4. Unpaid mortgage or indebtedness
a. Funeral expenses Actual on property;
expenses but not to exceed
5% of gross estate or
P200,000.00 whichever is
lower
b. Judicial expenses
c. Claims against insolvent
persons
d. Unpaid mortgages
Estate Tax
NIRC Provision NIRC TRAIN
Section 86 (A) 3. Property previously taxed; 5. Property previously taxed;
Allowable 4. Transfers for public use; 6. Transfers for public use;
deductions from the 5. Family home in the amount of 7. Family home, in the increased
gross estate of a ₱1,000,000.00; amount of ₱10,000,000;
citizen/resident 6. Medical expenses, not 8. Amounts received by heirs RA No.
exceeding ₱500,000; 4917 (Retirement benefits of
7. Amount received by heirs private firm employees)
under RA No. 4917
(Retirement benefits of private
firm employees)
Estate Tax
NIRC Provision NIRC
Section 86 (B) The value of the net estate of a
Allowable non-resident is determined by
deductions from the deducting the following from the
gross estate of a gross estate:
non-resident alien 1. Expenses, losses,
indebtedness, and taxes in
proportion to the value of
entire gross estate situated in
the Philippines;
2. Property previously taxed;
3. Transfers for public use
TRAIN
For Non-residents:
1. Standard deduction in the amount
of ₱500,000;
2. Value of
 Claims against the estate
 Claims against the insolvent
person
 Unpaid mortgages
In proportion to the value of the
entire gross estate situated in the
Philippines
3. Property previously taxed;
4. Transfers for public use
Estate Tax
NIRC Provision NIRC TRAIN
Section 86 (D) No deduction shall be allowed in Miscellaneous provision is deleted.
Miscellaneous the case of a non-resident not a
provision for non- citizen of the Philippines, unless
residents the executor, administrator, or
anyone of the heirs, as the case
may be, includes in the return
required to be filed under the
Section 90 the value at the time of
his death of that part of the gross
estate of the non-resident not
situated in the Philippines.
Estate Tax
NIRC Provision NIRC TRAIN
Section 89 Notice of decedent’s death shall be Requirement for filing of notice of
Notice of Death filed by the executor, administrator, death is removed.
or any of the legal heirs within two
months after death or after
qualifying as such executor or
administrator:
 In all cases of transfers subject
to tax
 In cases where though exempt
from tax, the gross value of the
estate exceeds ₱20,000.
Estate Tax
NIRC Provision NIRC TRAIN
Section 90 Estate tax returns showing a gross The threshold amount for the
Attachment to value exceeding ₱2,000,000 shall requirement of attaching a statement
Estate Tax Return – be supported with a statement duly duly certified by a CPA is increased
CPA certification certified by a CPA to ₱5,000,000 (from ₱2,000,000).

Section 90 Estate tax returns shall be filed The filing of estate tax returns shall
Time of filing of within six (6) months from the be within one (1) year from the
estate tax return decedent’s death. decedent’s death.
Estate Tax
NIRC Provision NIRC TRAIN
Section 91 (C) No provision In case the available cash of the
Payment by estate is insufficient to pay the total
installment of estate estate tax due, payment by
tax [new] installment shall be allowed within
two (2) years from the statutory date
of payments, without civil penalty and
interest.
Estate Tax
NIRC Provision NIRC
Section 97 If a bank has knowledge of the
Payment of tax death of a person, who maintained
antecedent to the a bank deposit account alone, or
transfer of shares, jointly with another, it shall not
bonds, or rights allow any withdrawal from the said
deposit account unless the
Commissioner has certified that
the taxes imposed thereon have
been paid.
TRAIN
If a bank has knowledge of the death
of a person, who maintained a bank
deposit account alone, or jointly with
another, it shall allow any withdrawal
from the said deposit account,
subject to a final withholding tax of
(6%).
DONOR’S
TAX
Donor’s Tax
NIRC NIRC TRAIN
Provision
Section 99 The donor’s tax for each calendar year shall be The donor’s tax for is fixed at 6%
Rates of tax computed on the basis of the total net gifts made based on annual total gifts exceeding
during the calendar year in accordance with the ₱250,000 (exempt gift), regardless of
graduated tax table. whether the done is a stranger or not.
NET GIFT TAX NET GIFT TAX
Not over ₱100,000 Exempt Over ₱1M but ₱44,000 + 8% of the
Over ₱100,000 but 2% of the excess not over ₱3M excess over ₱1M
not over ₱200,000 over ₱100,000 Over ₱3M but ₱204,000 + 10% of
Over ₱200,000 but ₱2,000 + 4% of not over ₱5M the excess over ₱3M
not over ₱500,000 the excess over Over ₱5M but ₱404,000 + 12% of
₱200,000 not over the excess over ₱5M
Over ₱500,000but ₱14,000 + 6% of ₱10M
not over ₱1M the excess over Over ₱10M ₱1,004,000 + 15% of
₱500,000 the excess over
₱10M
Donor’s Tax
NIRC Provision NIRC TRAIN
Section 99 The donor’s tax shall be 30% of The donor’s at is fixed at 6% based
Rates of tax the net gifts when the done or on annual total gifts exceeding
beneficiary is a stranger. ₱250,000 (exempt gift) regardless of
whether the donee is a stranger or
not.
Donor’s Tax
NIRC Provision NIRC
Section 100 The amount by which the fair
Transfer for less market value of the property
than adequate transferred exceeded the value of
consideration the consideration received for such
transfer, shall for purpose of
donor’s tax, be deemed a gift and
included in computing the amount
of gifts made during the year.
TRAIN
Additional proviso:
Even if the sale, exchange or other
transfer of property is for an
insufficient consideration, the same
will still be considered made for
adequate and full consideration
provided that such transfer is made in
the ordinary course of business, i.e.,:
 A bona fide transaction;
 At arm’s length; and
 Free from donative intent.
Donor’s Tax
NIRC Provision NIRC TRAIN
Section 101 Dowries or gifts made on account The exemption of dowries (gifts made
Exemption of of marriage by parents to each of on account of marriage) is removed.
certain gifts their legitimate, recognized ,
natural, or adopted children to the
extent of the first ₱10,000 shall be
exempt from donor’s tax.
VALUE
ADDED
TAX
 NIRC Provision NIRC
Section 106 (A)(2) The following are entitled to VAT zero-
Zero-rated Sale of rating:
Goods or Properties
1. The sale and actual shipment of
goods from the Philippines to a
foreign country, irrespective of any
shipping arrangement that may be
agreed upon which may influence
or determine the transfer of
ownership of the goods so exported
and paid for in acceptable foreign
currency or its equivalent in goods
or services, and accounted for in
accordance with the rules and
regulations of the Bangko Sentral
ng Pilipinas (BSP).
TRAIN
The following sales by VAT
registered persons shall be subject
to zero percent 0% rate:
1. The sale and actual shipment of
goods from the Philippines to a
foreign country, irrespective of
any shipping arrangement, paid
for in acceptable foreign currency
or its equivalent in goods or
services, and accounted for in
accordance with the rules and
regulations of the Bangko Sentral
ng Pilipinas (BSP).
 NIRC Provision NIRC TRAIN
Section 106 (A)(2) 2. Sale and delivery of goods to:
Zero-rated Sale of
Goods or Properties Registered enterprises within a
separate customs territory

Registered enterprises within tourism

enterprise zones

(The above provision was vetoed by

President Duterte because this go against
the principle of limiting the VAT zero-rating
to direct exporters.)
 NIRC Provision NIRC TRAIN
Section 106 (A)(2) 2. Sale of raw materials or 3. Sale of raw materials or packaging
Zero-rated Sale of packaging materials to a materials to a nonresident buyer
Goods or Properties nonresident buyer for for delivery to a resident local
delivery to a resident local export-oriented enterprise to be
export-oriented enterprise to used in manufacturing, processing,
be used in manufacturing, packing or repacking and paid for
processing, packing or in acceptable foreign currency and
repacking in the Philippines accounted for in accordance with
of the said buyer's goods and the rules and regulations of the
paid for in acceptable foreign Bangko Sentral ng Pilipinas (BSP).
currency and accounted for in
accordance with the rules
and regulations of the
Bangko Sentral ng Pilipinas
(BSP).
 NIRC Provision NIRC TRAIN
Section 106 (A)(2) 3. Sale of raw materials or 4. Sale of raw materials or
Zero-rated Sale of packaging materials to packaging materials to
Goods or Properties export-oriented enterprise export-oriented enterprise
whose export sales whose export sales exceed
exceed seventy percent seventy percent (70%) of
(70%) of total annual total annual production.
production.

4. Sale of gold to BSP.

 NIRC Provision NIRC TRAIN
Section 106 (A)(2) 5. Those considered export 5. Those considered export sales
Zero-rated Sale of sales under Executive Order under Executive Order No. 226,
Goods or Properties NO. 226, otherwise known otherwise known as the “Omnibus
as the “Omnibus Investment Investment Code of 1987”, and
Code of 1987”, and other other special laws; and
special laws.
6. The sale of goods, supplies,
6. The sale of goods, supplies, equipment and fuel to persons
equipment and fuel to engaged in international shipping
persons engaged in or international air transport;
international shipping or provided, that the goods, supplies,
international air transport equipment and fuel have been
operations. sold and used for international
shipping or air transport
operations.
 NIRC Provision NIRC TRAIN
Section 106 (A)(2) Additional provision:
Zero-rated Sale of Items 3, 4, and 5 shall be subject to the 12% VAT
Goods or Properties and no longer be considered export sales subject
to 0% VAT upon satisfaction of the following
conditions:
 There is a successful establishment and
implementation of an enhanced VAT refund
system that grants refunds of creditable input
tax within 90 days from the filing of the VAT
refund application with the Bureau.

 All pending VAT refund claims as of December

31, 2017 shall be fully paid in cash by
December 31, 2019.
 NIRC Provision NIRC TRAIN

Section 106 (A)(2) The Department of Finance shall establish a VAT

Zero-rated Sale of Refund Center in the BIR and BOC that will handle the
Goods or Properties processing and granting of cash refunds of creditable
input tax.
An amount equivalent to 5% of the total VAT collection
of the BIR and BOC from the immediately preceding
year shall automatically be appropriated annually and
shall be treated as a special account in the General
Fund or as trust receipts for funding VAT refund
claims.
Further, the BIR and BOC shall be required to submit
to the Congressional Oversight Committee on the
CTRP a quarterly report of all pending claims for
refund and any unused fund.
 NIRC Provision NIRC TRAIN
Section 106 (A)(2) Deleted provision:
Zero-rated Sale of
Goods or Properties The following shall no longer be subject to 0%
VAT:

1. Sale of gold to BSP

2. Foreign-currency denominated sales
Section 108 (A) Sale or exchange Sale or exchange of services include “sale of
Definition of Sale or of services include electricity by generation companies, transmission
Exchange of Services “sale of electricity by any entity including the National Grid
by generation Corporations of the Philippines [NGCP], and
companies, distribution companies, including electric
transmission, and Cooperatives”.
distribution
companies”
 NIRC Provision NIRC TRAIN
Section 108 (B) The following are entitled to VAT The following are entitled to VAT
Zero-rated Sale of zero-rating: zero-rating:
Services
1. Processing, manufacturing or 1. Processing, manufacturing or
repacking goods for other repacking goods for other
persons doing business persons doing business outside
outside the Philippines which the Philippines which goods are
goods are subsequently subsequently exported, where
exported, where the services the services are paid for in
are paid for in acceptable acceptable foreign currency and
foreign currency and accounted for in accordance with
accounted for in accordance the rules and regulations of the
with the rules and regulations Bangko Sentral ng Pilipinas
of the Bangko Sentral ng (BSP).
Pilipinas (BSP).
 NIRC NIRC TRAIN
Provision
Section 108 (B) 2. Services other than those 2. Services other than those
Zero-rated Sale mentioned in the preceding mentioned in the preceding
of Services paragraph, rendered to a person paragraph, rendered to a person
engaged in business conducted engaged in business conducted
outside the Philippines or to a outside the Philippines or to a
nonresident person not engaged nonresident person not engaged in
in business who is outside the business who is outside the
Philippines when the services are Philippines when the services are
performed, [51] the consideration performed, the consideration for
for which is paid for in acceptable which is paid for in acceptable
foreign currency and accounted foreign currency and accounted for
for in accordance with the rules in accordance with the rules and
and regulations of the Bangko regulations of the Bangko Sentral
Sentral ng Pilipinas (BSP); ng Pilipinas (BSP);
 NIRC NIRC TRAIN
Provision
Section 108 (B) 3. Services rendered to persons or 3. Services rendered to persons or
Zero-rated Sale of entities whose exemption under entities whose exemption under
Services special laws or international special laws or international
agreements to which the Philippines agreements to which the Philippines
is a signatory effectively subjects is a signatory effectively subjects the
the supply of such services to zero supply of such services to zero
percent (0%) rate; percent (0%) rate;
4. Services rendered to persons
engaged in international shipping or 4. Services rendered to persons
international air transport engaged in international shipping or
operations, including leases of international air transport operations,
property for use thereof; including leases of property for use
thereof: provided, that these services
shall be exclusively for international
shipping or air transport operations;
 NIRC NIRC
Provision
Section 108 (B) 5. Services performed by 5. Services
Zero-rated Sale subcontractors and/or contractors
of Services in processing, converting, or
manufacturing goods for an
enterprise whose export sales
exceed seventy percent (70%) of
total annual production;
TRAIN
performed by
subcontractors and/or contractors
in processing, converting, or
manufacturing goods for an
enterprise whose export sales
exceed seventy percent (70%) of
total annual production are no
longer entitled to VAT zero-rating.
 NIRC NIRC TRAIN
Provision
Section 108 (B) 6. Transport of passengers and 6. Transport of passengers and cargo
Zero-rated Sale cargo by domestic air or sea by domestic air or sea vessels from
of Services vessels from the Philippines to a the Philippines to a foreign country.
foreign country.
7. Sale of power or fuel generated
7. Sale of power or fuel generated through renewable sourced of
through renewable sourced of energy such as but not limited to
energy such as, but not limited to, biomass, solar, wind, hydropower,
biomass, solar, wind, hydropower, geothermal, ocean energy, and
geothermal, ocean energy, and other emerging energy sources
other emerging energy sources using technologies such as fuel
using technologies such as fuel cells and hydrogen fuels.
cells and hydrogen fuels.
 NIRC NIRC TRAIN
Provision
Section 108 (B) 8. Services rendered to:
Zero-rated Sale
of Services  Registered enterprises within a
separate customs territory

 Registered enterprises within

tourism enterprise

(Above provision was vetoed by

President Duterte)
 NIRC NIRC TRAIN
Provision
Section 108 (B) Additional provision:
Zero-rated Sale
of Services Items 1 and 5 shall be subject to the 12% VAT
and no longer be considered export sales subject
to 0% VAT upon satisfaction of the following
conditions:
 There is a successful establishment and
implementation of an enhanced VAT refund
system that grants refunds of creditable input
tax within 90 days from the filing of the VAT
refund application with the Bureau.

 All pending VAT refund claims as of December

31, 2017 shall be fully paid in cash by
December 31, 2019.
 NIRC Provision NIRC TRAIN

Section 108 (B) Additional provision:

Zero-rated Sale of
Goods or properties The Department of Finance shall establish a VAT
and zero-rated sale Refund Center in the BIR and BOC that will handle
of services the processing and granting of cash refunds of
creditable input tax.

To fund claims for VAT refund 5% of the total VAT

collection of the BIR and BOC from the immediately
preceding year shall be:

 Automatically appropriated annually.

 Treated as a special account in the General Fund
or as trust receipts.
 NIRC Provision NIRC TRAIN

Section 108 Additional provision:

Zero-rated Sale of
Goods or Properties The BIR and BOC shall submit to the
and Zero-rated Sale Congressional Oversight Committee on the
of Services Comprehensive Tax Reform Program a quarterly
report of all pending claims for refund and unused
fund.
 NIRC NIRC
Provision
Section 109 The following transactions, among others,
VAT-exempt are exempt from value-added tax:
Transactions (D) Importation of professional instruments
and implements, wearing apparel, domestic
animals, and personal household effects
(except any vehicle, vessel, aircraft,
machinery other goods for use in the
manufacture and merchandise of any kind in
commercial quantity) belonging to persons
coming to settle in the Philippines, for their
own use and not for sale, barter or
exchange, accompanying such persons, or
arriving within ninety (90) days before or
after their arrival,
TRAIN
The following are the changes on
VAT-exempt transactions:
(D) Importation of professional
instruments and implements, tools of
trade, occupation or employment,
wearing apparel, domestic animals,
and personal and household effects
belonging to persons coming to settle
in the Philippines or Filipinos or their
families and descendants who are
now residents or citizens of other
countries, such parties hereinafter
referred to as overseas Filipinos, in
quantities and of the class suitable to
the profession, rank or position of the
persons importing said items,
NIRC Provision NIRC TRAIN

Section 109 upon the production of for their own use and not for barter or sale,
VAT-exempt evidence satisfactory to the accompanying such persons, or arriving
transactions Commissioner, that such within a reasonable time: Provided, That
persons are actually coming to the Bureau of Customs may, upon the
settle in the Philippines and production of satisfactory evidence that
that the change of residence is such persons are actually coming to settle
bona fide. in the Philippines and that the goods are
brought from their former place of abode,
exempt such goods from payment of duties
and taxes:
NIRC Provision NIRC TRAIN

Section 109 Provided, further, That vehicles, vessels,

VAT-exempt aircrafts, machineries and other similar
Transactions goods for use in manufacture, shall not fall
within this classification and shall therefore
be subject to duties, taxes and other charges.
 NIRC NIRC TRAIN
Provision
Section 109 Sale of real properties not Sale of real properties not primarily held for sale to
VAT-exempt primarily held for sale to customers or held for lease in the ordinary course of
Transactions customers or held for lease trade or business or real property utilized for low-
in the ordinary course of cost and socialized housing, residential lot valued at
trade or business or real P1,500,000.00 and below; house and lot, and other
property utilized for low- residential dwellings valued at P2,500,000.00 and
cost and socialized below.
housing, residential lot
valued at P1,919,500.00 Beginning January 1, 2021:
and below; house and lot,  The VAT exemption shall not anymore apply to:
and other residential - Sale of low-cost housing
dwellings valued at - Sale of residential lot
P3,199,200.00 and below.  The threshold selling price amount for sale of
house and lot, and other residential dwellings
shall be P2,000,000.00
NIRC Provision NIRC TRAIN
Section 109 Every 3 years, the threshold Every 3 years, the threshold amount shall be
VAT-exempt amount shall be adjusted to adjusted to its present value using the
Transactions its present value using the Consumer Price Index, as published by the
Consumer Price Index, as Philippine Statistics Authority (PSA).
published by the National
Statistics Office.
Section 109 (Q) Lease of a residential (Q) Lease of a residential unit with a
VAT-exempt unit with a monthly rental not monthly rental not exceeding P15,000.00.
Transactions exceeding P12,800.00.

(U) Importation of fuel, (U) Additional provision:

goods and supplies by
persons engaged in Xxx Provided, That the fuel, goods, and
international shipping or air supplies shall be used for international
transport operations. shipping or air transport operations.
 NIRC Provision NIRC TRAIN

Section 109 Additional exempt transactions:

VAT-exempt
Transactions (W) Sale or lease of goods and services to
senior citizens and person with disabilities.

(X) Transfer of property in merger or

consolidation [under Section 40(C)(2) of
the NIRC/tax-free exchange].

(Y) Association dues, membership fees,

and other assessments and charges
collected by homeowners associations and
condominium corporations.
 NIRC Provision NIRC TRAIN

Section 109 (W) Sale or lease of goods (Z) Sale of gold to the BSP.
VAT-exempt or properties or the
Transactions performance of services (AA) Sale of drugs and medicines prescribed
other than the transactions for diabetes, high cholesterol, and
specifically mentioned as hypertension beginning January 1, 2019.
VAT-exempt, the gross
annual sales and/or Now (BB) Sale or lease of goods or
receipts do not exceed the properties or the performance of services
amount of P1,919,500.00 other than the transactions mentioned in the
(as amended). preceding paragraphs, the gross annual
sales and/or receipts do not exceed the
amount of P3,000,000.
 NIRC Provision NIRC TRAIN

Section 110 The input tax on the Amortization of input VAT shall only
(A)(2)(b) purchase of capital allowed until December 31, 2021.
Amortization of goods with a cost
Input VAT from exceeding After such date, taxpayers with
Purchases of P1,000,000.00 shall be unutilized input VAT on capital goods
Capital Goods amortized based on its purchased or imported shall be
useful life or 60 months, allowed to apply the same as
whichever is shorter. scheduled until fully utilized.
 NIRC Provision NIRC TRAIN

Section 112 The Commissioner shall  The period of granting by the Commissioner
Refunds or Tax grant a refund or issue a of refunds is decreased to 90 days (from 120
Credit of Input VAT tax credit certificate for days) from the date of submission of
creditable input taxes complete documents in support of the
within 120 days from the application.
date of submission of
complete documents.  The granting of tax credit instead of refund is
removed.

Additional provision:
Should the Commissioner find that the grant of
refund is not proper, the Commissioner must
sate in writing the legal and factual basis for
denial.
 NIRC Provision NIRC TRAIN

Section 112 Failure on the part of the The deemed denial of failure to act on the
Refunds or Tax Commissioner to act on application is removed.
Credit of Input VAT the application within the
period prescribed shall Additional provision:
be deemed a denial of
the application. Failure on the part of any official, agent, or
employee of the BIR to act on the application
within the ninety (90) – day period shall be
punishable under Section 269 of the Tax Code
(administrative fine and imprisonment).
 NIRC Provision NIRC TRAIN

Section 114 (A) VAT taxpayers shall file Beginning January 1, 2023, the filing and
Return and Payment quarterly return within 25 payment shall be done within 25 days
of VAT days following the close of following the close of each taxable quarter.
each taxable quarter,
while payment of the VAT
shall be made on a
monthly basis upon filing
of monthly VAT
declaration.
 NIRC Provision NIRC
Section 114 (B) Government or any of its
Withholding of VAT political subdivisions,
instrumentalities or agencies,
including government-owned
or -controlled corporations
(GOCCs) shall, before making
payment on account of each
purchase of goods and
services which are subject to
the value-added tax shall
deduct and withhold a final
value-added tax at the rate of
five percent (5%) of the gross
payment thereof.
TRAIN
Additional provision:
Beginning January 1, 2021, the VAT
withholding system shall shift from final
to a creditable system.
Payments for purchases of goods and
services arising from projects funded by
Official Development Assistance (ODA)
shall not be subject to the final
withholding tax system.
 NIRC NIRC TRAIN
Provision
Section 116 Cooperatives are exempt from Additional exemption:
3% gross receipts the 3% gross receipts tax
tax of persons Beginning January 1, 2019, self-
exempt from the employed and professionals with total
VAT annual gross sales and/or gross
receipts not exceeding P500,000 shall
be exempt from the 3% gross receipts

(The above provision was vetoed by

President Duterte because the
proposed exemption will result in
unnecessary erosion of revenues and
would lead to abuse and leakages.)
 NIRC NIRC TRAIN
Provision
Section 127 Sale, barter or exchange of shares of The rate of the stock transaction
Stock transaction stock listed and traded through the tax is increased to 6/10 of 1%
tax local stock exchange shall be subject
to a tax of ½ of 1% of the gross
selling price or gross value in money
of the shares of stock sold, bartered,
exchanged or otherwise disposed

Section 269 Additional provision:

Violations
committed by “(j) Deliberate failure to act on the
government application for refunds within the
enforcement prescribed period provided under
officers Section 112 of this Act.”
THE
END