11 February 2014
The Commissioner of Internal Revenue (“CIR”) has issued Revenue Regulations (“RR”) No. 3-2014 dated 11 February 2014 to amend Section 10 of RR No. 10-2010 (“Exchange of Information Regulations”).
Under RR No. 10-2010, a taxpayer should be notified by the CIR when a foreign tax authority is requesting for exchange of information held by financial institutions pursuant to an international convention or agreement on tax matters within sixty (60) days from receipt of request. As revised by RR No. 3-2014, the notification to the taxpayer may be made within six (6) calendar months if notification within the 60 day period will undermine the chances of success of the investigation conducted by the requesting foreign tax authority.
This regulation was published on 13 February 2014 in the Manila Bulletin and is effective immediately.