Tax Alerts

Updated policies on filing of appeal against Final Decision on Disputed Assessments (FDDA)

(Revenue Memorandum Circular No. 43-2023, issued on April 14, 2023)

This Tax Alert is issued to provide the updated policies on the filing of appeal against Final Decision on Disputed Assessments (FDDA) pursuant to Revenue Regulations (RR) No. 12-99, as amended.

In case of filing of an appeal against the FDDA, the taxpayer shall furnish a copy of the said appeal within five (5) days from date of filing with the Office of the Commissioner of Internal Revenue or the Court of Tax Appeals to the following:

  • Chief of the Assessment Division for regional cases; or
  • Concerned Head Revenue Executive Assistant, in case of taxpayers under the jurisdiction of the Large Taxpayers Service or investigated by the National Investigation Division under the Enforcement and Advocacy Service.