Unveiling the shift: understanding the difference between notice of informal conference and notice of discrepancy

Revenue Regulations 22-2020 requiring the issuance of a Notice of Discrepancy before issuing a Preliminary Assessment Notice (PAN).

The Notice of Discrepancy is somewhat not a new thing in the process. As early as 1998, the Bureau of Internal Revenue had issued Revenue Regulations 12-99 requiring the issuance of the Notice of Informal Conference. This was removed later on upon the issuance of Revenue Regulations 18-2013 and was reinstituted with the issuance of Revenue Regulations 7-2018 until it was replaced by the Notice of Discrepancy in 2022.

This question now comes to mind: what is the difference between a Notice of Discrepancy (NOD) and a Notice of Informal Conference (NIC)?

You may refer to below table for the easy comparison:

Item

Notice of Discrepancy (NOD)

Notice of Informal Conference (NIC)

Period to explain

Within a period of five (5) days from the receipt of the NOD

Within a period of ten (10) to fifteen (15) days and extendible up to thirty (30) days

Period to submit the documents

Within thirty (30) days from the receipt of the NOD

Within thirty (30) days from the receipt of the NOD

Non-Appearance on the scheduled date to discuss the discrepancy

Waiver of taxpayer’s right to discuss the discrepancy

Waiver of taxpayer’s right to discuss the discrepancy

Endorsement for issuance of Preliminary Assessment Notice

Within ten (10) days from the conclusion of the discussion

Within seven (7) days from the conclusion of the informal conference.

 

This article is for general information only and does not constitute professional advice. Therefore, the reader holds Morfe, Ceneta & Co., CPAs, including its partners, officers and employees free and harmless from any liability arising from one’s reliance on this article.