The BIR has issued Revenue Memorandum Circular (RMC) No. 43 – 2023 on filing of an appeal against the Final Decision on Disputed Assessment (FDDA) last April 14, 2023.  To note, the FDDA pertains to the final decision of the Commissioner of Internal Revenue (CIR) or his duly authorized representatives on the protest of Final Letter of Demand/Final Assessment Notice (FLD/FAN).

Pursuant to RMC No. 39-2013, taxpayers shall submit/files their protests (requests for reinvestigation/reconsideration) and other similar correspondences against the FLD/with the Office of the duly authorized representative of the CIR who issued the FLD/FAN.

In addition, in filing such an appeal against the FDDA, the taxpayer must also furnish a copy to the following people within five (5) days from the date of filing of the appeal with the Office of the Commissioner of Internal Revenue or the Court of Tax Appeals (CTA):

- Chief of the Assessment Division for regional cases, or

- Head Revenue Executive Assistant for taxpayers under the jurisdiction of the Large Taxpayers Service (LTS) or investigated by the National Investigation Division under the Enforcement and Advocacy Service

Please be guided accordingly.


P&A Grant Thornton
Certified Public Accountants
P&A Grant Thornton is the Philippine member firm of Grant Thornton International Ltd.


As published in SunStar Cebu, dated 27 April 2023