REVENUE REGULATIONS NO. 22-2018 issued on October 17, 2018 further amends Section 10 of Revenue Regulations (RR) No. 10-2010, as last amended by RR No. 10-2018 (“Exchange of Information Regulations”) relative to “Notice to Taxpayers”. A taxpayer shall be duly notified in writing by the Commissioner that a foreign tax authority is requesting for exchange of information held by financial institutions pursuant to an international convention or agreement on tax matters within sixty (60) days following the transmittal of all information requested from, and provided for by, the concerned financial institution to the requesting treaty partner; or in cases where notification is likely to undermine the chance of success of the investigation conducted by the requesting jurisdiction, and the requesting jurisdiction has made a substantiated request for a deferment of the notification based on these grounds, notice to the taxpayer must only be given after receipt of communication from the requesting jurisdiction that the investigation has already attained finality.