Legal Insights

Plain-language guides and case briefs on Philippine law — researched from the firm's law library of 184,000+ statutes, Supreme Court decisions, and agency issuances, and written so non-lawyers can understand and act on them.

Showing 17 of 7 articles for preliminary assessment notice

Defective Tax Waivers: Supreme Court Voids BIR Assessment Against Telstar

Supreme Court voids BIR deficiency assessment against Telstar due to defective waivers and lack of demand for payment, reinforcing strict rules on prescriptive periods.

Tax Assessment Time Limits: How a Missed Deadline Can Save You Millions

Philippine Supreme Court ruling on tax assessment prescription periods, false returns, and why the BIR's missed deadlines can invalidate deficiency assessments.

Letter of Authority vs. Letter Notice: When a BIR Tax Assessment Is Void

The Supreme Court ruled that a BIR Letter Notice cannot substitute for a Letter of Authority—assessments without a valid LOA are void.

Retroactivity of Tax Rulings Clarifying Documentary Stamp Tax on Intercompany Advances

Supreme Court clarifies when tax rulings apply retroactively, affecting documentary stamp tax on intercompany advances and refund claims.

Letter of Authority Required When Reassigning Tax Audits: Supreme Court Ruling

Supreme Court nullifies tax assessments where audits were reassigned without a new Letter of Authority. Learn the rules.

Due Process in Tax Assessments: Strict Adherence to Notice Requirements

The Supreme Court nullified a deficiency tax assessment because the BIR issued the Final Assessment Notice before the taxpayer's 15-day period to reply to the Preliminary Assessment Notice lapsed.

Tax Collection Prescription: CIR's Collection Efforts Barred by Three-Year Period

Supreme Court affirms CTA ruling that the CIR's right to collect deficiency taxes prescribed after three years from assessment notice.