Prescribing the Standard Format in the Numbering of Deficiency Tax Assessments Notices

March 7, 2022 REVENUE MEMORANDUM ORDER NO. 23-2022 SUBJECT : Prescribing the Standard Format in the Numbering of Deficiency Tax Assessments Notices Pursuant to Revenue Regulations (RR) No. 12-99, as Amended and Revenue Memorandum Circular (RMC) No. 3-2022 TO : All Regional Directors, Revenue District Officers, Chiefs of the Assessment Divisions and All Internal Revenue Officers Concerned I. OBJECTIVES To prescribe a standard format in the numbering of Preliminary Assessment Notice (PAN), Formal Letter of Demand (FLD)/Final Assessment Notice (FAN) and Final Decision on Disputed Assessment (FDDA), herein referred to as Assessment Notices. II. GUIDELINES 1. The assessment notices for deficiency basic tax, surcharge and interest (Part I) prescribed in RR No. 12-99, as amended and assessment notices for compromise penalties (Part II) prescribed in Revenue Memorandum Circular No. 3-2022 along with the Details of Discrepancies (DOD) attached thereto shall be issued in triplicate to be distributed as follows: Original Taxpayer's copy, Duplicate To be attached to the docket of the case, and Triplicate File copy of the approving office. 2. The PAN shall be numbered based on a uniform system containing 43 characters using the following format: P - 000000000000 - 000000-000-0000-000000 - 00000 LA Serial No. Audit Case No. Sequence No. Illustration: Assuming for the year 2021, the first PAN that was issued by the Assessment Division (AD) of RR No. 8A-Makati City was pursuant to eLA No. 201900054321 with LOA No./Case ID No. AUDT05-047-2021-123456 issued by RDO No. 47-East Makati covering taxable year 2019. It shall be numbered as follows: P - 201900054321 - AUDT05-047-2021-123456 - 00001 The sequence number shall be reset to start again from "00001" at the beginning of each year. Thus, the first PAN to be issued by the AD in the year 2022 shall be numbered as "P-000000000000-000000-000-0000-000000- 00001 ." 3. The FLD/FAN shall likewise use the same combination from the originating PAN. However, "P" shall be replaced with "F" to distinguish it from the PAN. a. For FLD, the following format shall be used: F - 000000000000 - 000000-000-0000-000000 - 00000 LA Serial No. Audit Case No. Sequence No. Illustration: Assuming the PAN No. "201900054321-AUDT05-047-2021-123456-00001" was not paid in whole or in part, the unpaid portion of the deficiency tax assessment per issued PAN shall be reflected in the FLD/FAN. It shall be numbered as follows: F - 201900054321 - AUDT05-047-2021-123456 - 00001 b. For FAN which is documented in the Final Assessment Notice (BIR Form No. 0401), it shall include the code corresponding to the tax type being assessed. Hereunder is the format to be used: F - 00 000000000000 - 000000-000-0000-000000 - 00000 Tax Type Code LA Serial No. Audit Case No. Sequence No. Illustration: Assuming that the unpaid portion covers the deficiency income tax and value-added tax, the FAN for each tax type shall be numbered as follows: F - IT 201900054321 - AUDT05-047-2021-123456 - 00001 F - VT 201900054321 - AUDT05-047-2021-123456 - 00001 It shall be reiterated that the combination "201900054321-AUDT05-047-2021-123456-00001" from the originating PAN is retained. Furthermore, a corresponding FAN shall be issued for every tax type. 4. The same combination from the originating PAN shall be used in numbering the FDDA except that "P" shall be replaced with "D" following the format below: D - 000000000000 - 000000-000-0000-000000 - 00000 LA Serial No. Audit Case No. Sequence No. All decisions on protest to the FLD/FAN, whether the taxpayer's protest is accepted or denied partially or wholly, shall be communicated to the taxpayer through the issuance of a FDDA together with the FAN bearing the amended deficiency tax assessment. However, to effect the issuance of the FDDA/FAN, the protested FAN shall first be cancelled. Illustration: Assuming that the above issued FLD/FAN was disputed in whole or in part, and the protest is denied, in whole or in part, the previous FAN shall first be cancelled before issuing the amended FAN together with a FDDA which shall be numbered as follows: D - 201900054321 - AUDT05-047-2021-123456 - 00001 Whenever a replacement electronic Letter of Authority (eLA) is issued due to reassignment of the case to another Revenue Officer/Group Supervisor, as prescribed under existing revenue issuances, the applicable letter of demand/assessment notice shall now bear the recent LA Serial Number and Audit Case Number. III. REPEALING CLAUSE All other issuances inconsistent herewith are hereby modified or repealed accordingly. IV. EFFECTIVITY This Order shall take effect immediately. CAESAR R. DULAY Commissioner of Internal Revenue By: (SGD.) MARISSA O. CABREROS Deputy Commissioner Legal Group Officer-in-Charge