Taxpayers requesting for a copy of the decision of the Commissioner of the Bureau of Internal Revenue (BIR) on an administrative appeal against a final decision on disputed assessment and on the denial of the claims for refund of value-added tax (VAT) and excise tax (ET) must submit certain documents and follow specific steps for faster processing of their requests, according to a new BIR policy.
The state tax collector has released Revenue Memorandum Order (RMO) No. 34-2025 on the guidelines and procedures for the processing of requests for a Certified True Copy (CTC) of the BIR Commissioner’s decision on an administrative appeal against a Final Decision on Disputed Assessment (FDDA) and on a denial of the claims for refund of VAT and EX under the jurisdiction of the Appellate Division.
To recall, in tax assessment, the BIR must ensure that the taxpayers are declaring and paying the correct amount of taxes, whereas the taxpayers may exhaust all administrative remedies to challenge any alleged tax deficiency before seeking relief from the courts.
As such, one administrative remedy at the taxpayer’s disposal is the filing of a request for reconsideration or reinvestigation of the BIR’s assessment pertaining to tax matters. The assessment then becomes a disputed assessment, and the Commissioner of Internal Revenue is duty bound to resolve and decide on the disputed assessment. This decision is known as the “Final Decision on Disputed Assessment (FDDA).”
Under RMO 34-2025, among the documents required is a written request for a CTC of the Commissioner’s decision. The request should include the taxpayer’s name and the taxable year involved and should be signed by the taxpayer or the authorized representative.
Additionally, individual taxpayers must submit a photocopy of one government-issued identification card showing the taxpayer’s name, picture and signature, and with one specimen signature.
If transacting through a representative, the BIR must be provided an original copy of a Special Power of Attorney executed by the taxpayer, and a photocopy of one government-issued ID for both the taxpayer and the authorized representative, showing their names, pictures, and signatures, and with one specimen signature each.
For corporations, they are required to present one original copy of a Board Resolution, Written Resolution if a one-person corporation, or Secretary’s Certificate, indicating the purpose and the name of the authorized representative; and a photocopy of one government-issued ID for both the signatory and the authorized representative, showing their names, pictures, and signatures, and with one specimen signature each.
All taxpayers filing the request should also provide proof of payment of the certification fee issued by the General Services Division (GSD) of the BIR National office, and payment of documentary stamp tax.
The taxpayer should then submit the written request for a CTC of the Commissioner’s decision, along with the proof of identification and authorization, to the Administrative Officer of the Appellate Division at Room 807, 8/F, BIR National Office for processing.
The taxpayer next pays the P100 fee per CTC to the GSD at Room 1011, 10/F, BIR National Office, and pays for the documentary stamp tax. Both proof of payment issued by the GSD and the loose DST must be presented to the Appellate Division.
Once this is done, the taxpayer receives from the Appellate Division the requested CTC of the BIR chief’s decision.
RMO 34-2025, issued on July 7, 2025 and signed by Commissioner Romeo Lumagui, Jr., takes immediate effect.
