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Breakdown of disputed items (e.g., Deficiency Income Tax, Deficiency VAT) followed by your legal arguments for each. Conclusion:
To be considered valid and have "force and effect," a protest letter must include the following details per :
The reference number, date, and type of tax covered by the FAN/FLD.
If your protest is denied, you have 30 days to appeal to the .
[Taxpayer's Name], of legal age, after having been duly sworn in accordance with law, hereby depose and state that:
(Note: For local taxes, a verification/certification against forum shopping is also required.)
[Signature] [Printed Name of Taxpayer or Authorized Representative] Key Requirements for Validity
The assessment alleges that the taxpayer underdeclared its sales by Php [Amount] based on a third-party information (TPI) matching.
| Tax Type | Amount (₱) | | :--- | :--- | | Deficiency Income Tax | [Amount] | | Deficiency Value-Added Tax (VAT) | [Amount] | | Deficiency Expanded Withholding Tax (EWT) | [Amount] | | Compromise Penalty | [Amount] | | | ₱[Total Amount] |
III. Grounds of Protest (Legal and Factual Objections) A. Lack of Legal Basis / Misapplication of Law
Include applicable laws, rules, regulations, or jurisprudence. Be filed within 30 days.
Understanding and Drafting a Protest Letter for a Tax Assessment in the Philippines
If the BIR denies your protest via an FDDA, or if they fail to act on your protest within 180 days from the submission of supporting documents, you have 30 days to appeal the decision or inaction to the Court of Tax Appeals (CTA) or file an administrative appeal with the Commissioner of Internal Revenue (CIR).
The BIR disallowed legitimate business expenses for [Reason], despite submission of valid receipts.
