REVENUE MEMORANDUM ORDER NO. 23-2022 issued on April 27, 2022 prescribes
the standard format in the numbering of deficiency tax assessment notices pursuant to
Revenue Regulations (RR) No. 12-99, as amended and Revenue Memorandum Circular
(RMC) No. 3-2022.
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 RMC 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
Triplicate – File copy of the approving office
The Preliminary Assessment Notice (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.
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”.
The Formal Letter of Demand (FLD)/Final Assessment Notice (FAN) shall likewise
use the same combination from the originating PAN. However, “P” shall be replaced with
“F” to distinguish it from the PAN.
For FLD, the following format shall be used:
F – 000000000000 – 000000-000-0000-000000 – 00000
LA Serial No. Audit Case No. Sequence No.
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.
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.
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.