Tax & BIR

A notice received.
A response considered.

Start with the document, the deadline and the records.

Illustrative tax-review folders and unbranded records

BIR Notice Review & Response Plan

Received a BIR notice? Understand it before your company responds.

A structured legal review of the document, applicable deadlines, requested records, immediate issues, and next steps before full audit defense or protest work begins.

Professional fee

Subject to the firm’s quotation

Professional fees are VAT-exclusive.

This is a limited-scope legal engagement. Conflict clearance and written engagement confirmation are required before representation begins.

Intended client: Management of one taxpayer that has received a principal BIR notice or related correspondence.
Initial deliverable: Written notice review, deadline map, management action plan and one lawyer conference.
Principal scope: Initial notice, authority and procedural-stage review with approximately 50 pages of supporting material. PAN, FLD/FAN and FDDA matters require careful scope screening.
Material exclusions: No full BIR audit defense, substantive protest preparation or filing, tax computation, accounting or CTA representation.

A close deadline?

State the date received and any deadline shown in the document when requesting a conflict check. NLF will first determine fit, conflicts, and whether the limited service is appropriate.

Request Conflict Check & Scope Confirmation

Submitting an inquiry does not create an attorney-client relationship. Engagement is subject to conflict checking and written acceptance.

Choose the form of engagement

Different needs. Different scopes.

Consultation

Focused initial assessment and oral guidance during an agreed session. Further work is separately scoped.

Consultation scope

Defined project

A specified issue, document set and deliverable. A diagnostic does not include every corrective step or ongoing representation.

Business review scope

Ongoing counsel

Recurring routine capacity for the named client, within plan limits. Substantial projects and disputes require separate scope.

Counsel scope

Business Legal Risk Review spans selected corporate, contractual, employer, tax-process and compliance risks. Corporate Compliance & Governance Review focuses more narrowly on corporate records, governance, authority, reportorial position and account custody. They are distinct engagements.

The document type and procedural stage matter.

What did you receive?

“BIR notice” is a useful business term, but the documents do not perform the same legal function. An eLA or LOA, Mission Order, and Tax Verification Notice can involve different authority and scope questions. A Notice of Discrepancy, PAN, FLD/FAN, or FDDA may place the matter at a different stage and may require a different or additional substantive response.

Audit or verification authority

eLA/LOA, Mission Order, and Tax Verification Notice. The review considers the stated authority, scope, covered periods, requests, and process.

Findings, assessment, or dispute stage

Notice of Discrepancy, PAN, FLD/FAN, and FDDA. These can call for immediate deadline and engagement assessment rather than a routine review alone.

Why early review matters

Early legal review helps management cooperate appropriately while controlling the legal and documentary process deliberately. Before responding or producing records, management should understand who issued the document, what it appears to cover, what dates matter, which records to preserve, and what needs legal or accounting clarification.

Understand the document

Identify the authority, stated taxpayer, covered periods, requests, receipt details, and apparent procedural stage.

Organize the record

Create a controlled inventory of available and missing records before documents are produced or explanations are made.

Coordinate management action

Assign responsible business functions, preserve relevant material, and identify points that need legal or accounting clarification.

A written legal review and management action plan, not merely an oral consultation.

What the client receives

Notice & authority review

Identify the document, stated taxpayer, covered period, scope, and material authority or procedural points apparent from the materials provided.

Deadline map

Separate material response dates from the notice, administrative dates, conference dates, and deadlines that require confirmation under the actual procedural stage.

Scope analysis

Explain what tax type, period, transaction, books, records, or issue the document appears to cover.

Document inventory

Organize requests, identify unclear or missing items, and distinguish records already available from records management still needs to locate.

Initial issues map

Identify early legal and procedural questions apparent from the notice and initial records. This is not a complete tax exposure computation.

Document-production protocol

Recommend an orderly process to identify, review, preserve, log, and produce responsive records appropriately.

Clarification list

Identify what management, finance, accounting, or other personnel should confirm before a substantive response is made.

Management action plan

Set out immediate actions, responsible functions, records to preserve, escalation points, and the recommended next legal stage, if any.

Lawyer conference

One conference with management to discuss the written review and immediate next steps.

What this service does not include

This is not full audit defense. It answers the initial management question: what did we receive, what does it require, what should be preserved or prepared, and what should happen next?

Full BIR audit representation or repeated BIR conferences
Preparation or filing of substantive PAN, FAN/FLD, reconsideration, reinvestigation, collection-defense, or CTA pleadings
Tax-liability, accounting, bookkeeping, tax-return, or reconstruction work
Extensive forensic review, broad witness interviews, affidavits, litigation, or government appearances
More than one taxpayer, multiple principal notices, materially separate taxable-period analyses, or substantially more than approximately 50 pages of initial supporting material

Excluded work may be separately evaluated, scoped, and quoted where necessary.

A defined process for an initial BIR notice review

Step 1
Request conflict check
Step 2
Scope confirmation
Step 3
Engagement and payment
Step 4
Secure document submission and legal review
Step 5
Written plan and lawyer conference

If the matter requires further representation

A review may identify a need for separate BIR Audit Defense, PAN/FAN protest work, collection defense, or Court of Tax Appeals proceedings. Further work is not included in this service and is separately evaluated, scoped, quoted, and accepted. Not every matter progresses through each stage.

Explore Tax & BIR legal services

Frequently asked questions

What BIR documents can we submit for initial screening?

The service may be suitable for an eLA or LOA, Mission Order, Tax Verification Notice, Notice of Discrepancy, or other BIR audit or verification correspondence. PAN, FLD/FAN, and FDDA matters are screened carefully because a separate substantive response engagement may be needed.

Does this service include BIR representation?

No. It is a limited review, written action plan, and one lawyer conference. Further representation is separately evaluated, scoped, quoted, and accepted in writing.

Does it include a PAN or FAN protest?

No. The document may be reviewed within the limited engagement, but substantive protest preparation and filing are separate work.

Can our accountant join the conference?

Yes, where management considers it useful. The initial review may identify information that finance or accounting personnel should clarify.

What if the deadline is very close?