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AAC Tax Code.

The National Internal Revenue Code of 1997 as it currently stands — consolidated by the firm to carry the TRAIN Law, the CREATE Act, the Ease of Paying Taxes Act, the VAT on Digital Services Act, CREATE MORE, the CMEPA and the amendatory laws in force to 1 August 2026, with a footnote at every provision naming the law that changed it.

Text current as at 1 August 2026. This is an unofficial consolidation prepared by the firm and not the official text of the Code. Repealed provisions are kept, struck through, so that references in earlier records stay traceable.
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The printed edition runs to 240 pages and carries the same text, footnotes and references as the browser below. Every section here shows the page it sits on in that PDF, so a citation taken from the screen matches the one taken from the book.

TITLE VIII — REMEDIES › CHAPTER III. PROTESTING AN ASSESSMENT, REFUND, ETC.

SEC. 228. Protesting of Assessment

Page 152 of the PDF edition

When the Commissioner or his duly authorized representative finds that proper taxes should be assessed, he shall first notify the taxpayer of his findings: Provided, however, That a preassessment notice shall not be required in the following cases:

(a) When the finding for any deficiency tax is the result of mathematical error in the computation of the tax as appearing on the face of the return; or

(b) When a discrepancy has been determined between the tax withheld and the amount actually remitted by the withholding agent; or

(c) When a taxpayer who opted to claim a refund or tax credit of excess creditable withholding tax for a taxable period was determined to have carried over and automatically applied the same amount claimed against the estimated tax liabilities for the taxable quarter or quarters of the succeeding taxable year; or

(d) When the excise tax due on excisable articles has not been paid; or

(e) When an article locally purchased or imported by an exempt person, such as, but not limited to, vehicles, capital equipment, machineries and spare parts, has been sold, traded or transferred to non-exempt persons.

The taxpayers shall be informed in writing of the law and the facts on which the assessment is made; otherwise, the assessment shall be void.

Within a period to be prescribed by implementing rules and regulations, the taxpayer shall be required to respond to said notice. If the taxpayer fails to respond, the Commissioner or his duly authorized representative shall issue an assessment based on his findings.

Such assessment may be protested administratively by filing a request for reconsideration or reinvestigation within thirty (30) days from receipt of the assessment in such form and manner as may be prescribed by implementing rules and regulations. Within sixty (60) days from filing of the protest, all relevant supporting documents shall have been submitted; otherwise, the assessment shall become final.

If the protest is denied in whole or in part, or is not acted upon within one hundred eighty (180) days from submission of documents, the taxpayer adversely affected by the decision or inaction may appeal to the Court of Tax Appeals within thirty (30) days from receipt of the said decision, or from the lapse of the one hundred eighty (180)-day period; otherwise, the decision shall become final, executory and demandable.

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