Summary
RMC No. 34-2014 clarifies whether an assessment from jeopardy or arbitrary assessment, or one based on the “best evidence obtainable” method, is a “doubtful assessment” under Section 3 of RR No. 30-2002 for compromise settlement applications.
Key points
- Not automatically doubtful. An assessment based on the “Best Evidence Obtainable Rule” is not automatically considered a doubtful assessment. The circumstances behind it must be thoroughly evaluated.
- Presumption of correctness. When a taxpayer fails to present the documents needed to assess its tax liability, the BIR must use the best evidence obtainable method to recover unpaid taxes. An assessment made this way is presumed prima facie correct and sufficient for all legal purposes.
Who is affected
- Taxpayers applying for compromise settlement under RR No. 30-2002
Deadlines and effectivity
- Issued May 8, 2014
Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.
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