RR No. 06-2000: Prescribes the regulations to implement the compromise settlement of internal revenue tax liabilities of taxpayers with outstanding receivable accounts and disputed assessments with the Bureau

Key points

1. Cases that may be compromised. These are delinquent accounts, cases under administrative protest pending in the Regional Offices, Revenue District Offices, Legal Service, Large Taxpayers Service (LTS), Enforcement Service, Excise Taxpayers Service (ETS) and Collection Service. They also include civil tax cases disputed in court, collection cases filed in courts, and criminal violations other than those already filed in court or involving criminal tax fraud.
2. Cases that cannot be compromised. These are withholding tax cases, criminal tax fraud cases, and criminal violations already filed in court. Delinquent accounts with a duly approved schedule of installment payments are also excluded.
3. Grounds for acceptance. A compromise is accepted on the basis of doubtful validity of the assessment or financial incapacity.
4. Minimum rates. The minimum rates, per tax type assessment, are 40% for doubtful validity and 10% for financial incapacity. For delinquent accounts and disputed assessments of taxpayers registered under the LTS and ETS, the minimum is 50%.
5. Who approves. The National Evaluation Board handles basic assessed tax exceeding P 1 Million and offers below the minimum rates. The Regional Evaluation Board handles basic assessed tax of P 500,000.00 or less. The Commissioner of Internal Revenue handles basic assessed tax exceeding P 500,000.00 but not over P1 Million.

Who is affected

• Taxpayers with outstanding receivable accounts and disputed assessments

Deadlines and effectivity

• Issued September 25, 2000