Responding to a BIR Final Assessment Notice: Deadlines That Decide Cases

By Atty. Ray John Bangi. Published 2025-12-12.

The 30-Day Rule

You have 30 days from receipt of the FAN to file a written protest with the BIR. Missing this deadline ends your right to contest.

Reconsideration vs Reinvestigation

A request for reconsideration is decided on existing records. A request for reinvestigation allows submission of new evidence — but you have 60 days from filing the protest to submit supporting documents.

After the Decision

If the protest is denied or unacted upon for 180 days, you may appeal to the Court of Tax Appeals within 30 days.

Building Your Defense

• Reconcile the deficiency computation against your records
• Identify procedural defects (LOA validity, period of audit, notices)
• Apply substantive arguments — exemptions, deductions, treaties
• Consider compromise settlement where applicable

Why Speed Matters

Most successful BIR defenses begin in the first week. Engage tax counsel immediately on receipt of any deficiency notice.

Contact Eleazar Bangi & Associates Law Firm

Office: 511 Bell Mansion, Bagong Pag-asa, Quezon City, Metro Manila 1105, Philippines. Hours: Monday to Friday, 9:00 AM to 6:00 PM. Email: rjbangi@reblegal.com. WhatsApp and Viber available. Contact us.