BIR audit and assessment defense

Received a letter from the BIR?
Reply on time, with the law on your side.

We prepare replies and protests to BIR audit notices, from the Letter of Authority to the Final Decision on Disputed Assessment. Every argument is tied to the exact provision of the Tax Code, revenue regulation or court decision it relies on, and procedural defenses are checked first.

Letter of Authority / eLANotice of DiscrepancyPreliminary Assessment Notice Final Assessment Notice / Formal Letter of DemandFinal Decision on Disputed Assessment
How it works

From notice to filed reply

Send us the notice

Share the BIR letter and the date you received it. We identify the stage and compute your deadline the same day.

Procedural review

Before the merits, we check the Letter of Authority, prescription per return, service of the notice and due process. These are often the strongest defenses.

Reconciliation and research

We recompute the BIR's figures from your own records and research each finding in primary sources: the Tax Code, regulations, circulars and CTA and Supreme Court decisions.

Draft, citation check, review

You receive a plain Word reply for your letterhead. Every quotation is verified against its source before you see it, and nothing is filed without your review.

File and track

After filing, we track the next deadlines and the BIR's own time limits, including the last day it can issue an assessment for each return.

Estimate your exposure

We show what each finding is worth in pesos, with basic tax, interest and surcharge, under the BIR's position and under our defense.

Services

What we handle

Fees depend on the number of findings, taxes and periods involved and are agreed with you before any work begins.

LOA / eLA, Notice of Discrepancy

Reply to audit letters and discrepancy notices

  • Classification of the notice and deadline
  • Review of the LOA and prescription
  • Reconciliation of the BIR's findings to your records
  • Written reply with annexes
Starts at ₱100,000
PAN

Reply to a Preliminary Assessment Notice

  • Point-by-point reply to each finding
  • Procedural defenses (prescription, due process)
  • Recomputation of the assessment
  • Filed within the 15-day period
FAN / FLD

Protest of a Final Assessment

  • Request for reconsideration or reinvestigation
  • Protest filed within 30 days
  • Supporting documents within 60 days
  • Tracking of the BIR's 180-day period
FDDA

Decision on disputed assessment

  • Review of the decision and options
  • Request for reconsideration with the Commissioner, or
  • Support for your lawyer's appeal to the Court of Tax Appeals
Prescription review

Has the BIR's time to assess run out?

  • Last day to assess, computed per return
  • Review of any waiver signed
  • Watch dates for open periods
Before an audit

Pre-audit health check

  • Returns vs. books and financial statements
  • Withholding tax and deductibility review
  • VAT and zero-rating support
  • List of exposures and fixes

Appeals to the Court of Tax Appeals are filed by your lawyer; we support with the tax analysis, computations and documents. Fees exclude government charges and notarial fees.

Free tool

When is my reply due?

Pick the notice you received and the date you received it (not the date printed on it).

Rules applied: LOA documents 10 days; NOD 30 days; PAN 15 days; FAN/FLD protest 30 days (documents 60 days after the protest); FDDA 30 days. A deadline on a weekend or national holiday runs to the next working day. This is general information, not advice on your case: some notices state their own period, and local holidays are not included.

Your deadline
Select a date
Book a consultation
How we work

Careful, cited, confidential

Primary sources, checked

We maintain our own library of BIR issuances, Tax Code versions by year, and CTA and Supreme Court decisions. Every quotation in a reply is checked word for word against its source, for the version in force for your taxable year.

Procedural defenses first

Prescription, the validity and service of the Letter of Authority, and due process are reviewed before the merits. An assessment issued out of time or without due process can be void regardless of the amounts.

Your records, recomputed

We rebuild the BIR's schedules from your books and returns, looking for double counting, wrong inputs and periods that have prescribed.

Confidential by design

Client names and TINs are kept out of working drafts and filled in only at the end. Documents are received through a private channel, never through the website chat. See our privacy notice.

For accountants and firms

Refer an audit case

If your client received a BIR notice and you would rather not handle the dispute, refer the case. You stay the client's accountant; we handle the reply. With your client's consent, you receive status updates at each stage.

Discuss a referral

What referring CPAs receive

  • Confirmation of the stage and deadline
  • Status updates when the reply is filed and when the BIR responds
  • Your client relationship is kept with you

Case documents and drafts are shared only with the client, as required by our engagement and privacy terms.

FAQ

Common questions

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Outsourced accounting and payroll

For businesses in the USA, Canada and Europe: QuickBooks Online and Desktop setup, cleanup and support; monthly bank and account reconciliation; payroll processed on time each cycle.

Ask about outsourced accounting
Consultation

Book a consultation

Choose a time that suits you. Have the BIR notice and the date you received it ready. Please do not send documents until we confirm the engagement; we will send you a private upload link.

Open the booking calendar

Deadline in the next 3 days? Message us directly on Viber or WhatsApp.

Contact

Email: info@cpa.one
Viber / WhatsApp: +63 962 817 6610
Manila, Philippines