RR No. 22-2018: Further amends Section 10 of Revenue Regulations (RR) No. 10-2010, as last amended by RR No. 10-2018, relative to “Notice to Taxpayers”

Key points

1. Notice rule. The Commissioner notifies a taxpayer in writing that a foreign tax authority is requesting exchange of information held by financial institutions under an international convention or agreement on tax matters. Notice is given within sixty (60) days following the transmittal of all requested information from the financial institution to the requesting treaty partner.
2. Deferred notice. If notification is likely to undermine the investigation and the requesting jurisdiction has made a substantiated request for deferment, notice is given only after the requesting jurisdiction communicates that the investigation has attained finality.

Who is affected

• Taxpayers whose financial institution information is requested by a foreign tax authority

Deadlines and effectivity

• Notice within sixty (60) days following transmittal of the requested information