Flashcards Studio

Orionis Tech Solutions, Inc., a VAT-registered taxpayer, receives a Final Assessment Notice (FAN) for 2024 indicating a VAT deficiency of ₱3,100,000 arising from misclassification of input VAT. The FAN states the tax type (VAT), the year (2024), the deficiency amount, the deficiency reason, and includes a full computation schedule with supporting data. On the same day, the BIR issues a separate Collection Demand directing payment of ₱3,100,000 within 15 days; the Demand states the tax type, the period (2024), the amount due, and that the period and the basis are “consistent with FAN,” but provides only a single-line computation instead of a full schedule. Five days later, the BIR levies Orionis’ corporate bank account to satisfy the amount. The taxpayer contends the levy is void for lack of essential requisites. (a)Identify the requisites of a valid final assessment under the NIRC and the requisites of a valid collection demand. (b)Distinguish, with brief rationale, the controlling rule that makes a levy valid when all requisites are present versus invalid when any requisite is missing. (c)Apply to the facts and determine whether the levy is proper, and outline Orionis’ possible remedies.