0962 234-1368 0936 942-9617 0917 104-1408 qsplawoffice@gmail.com
BGC, Taguig City
Practice Area

Tax Lawyers in the Philippines

CPA-Lawyers who fight BIR audits, resolve assessments, and protect your business from tax liabilities.

Tax Law Philippines

The Only Tax Lawyers Who Are Also Certified Public Accountants

Most tax disputes are fundamentally accounting problems dressed in legal clothing. A BIR audit challenges how your books were kept, how income was recognized, and how deductions were computed. A purely legal response — without deep accounting knowledge — leaves money on the table.

At QSP Law Office, every partner holds both a CPA license and a law license. We read your financial statements the way a BIR examiner does — and we know exactly where they are right, where they are wrong, and how to prove it.

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Our Tax Law Services

What We Handle

From BIR audit defense to CTA litigation, we cover every stage of the Philippine tax dispute process.

BIR Audit Defense

We represent you during BIR examinations — reviewing documents, responding to examiners, and limiting your exposure before an assessment is issued.

Deficiency Assessment Protest

We draft and file protests against Preliminary and Final Assessment Notices (PAN/FAN), attacking both the legal basis and the accounting methodology of the assessment.

VAT Disputes & Refund Claims

We handle VAT deficiency cases and pursue excess input VAT refunds or tax credit certificates (TCCs) through the BIR and CTA.

Court of Tax Appeals (CTA) Litigation

When BIR denies your protest, we bring your case to the CTA — the specialized tax court — with full knowledge of its procedures and jurisprudence.

Estate Tax Computation & Filing

We compute estate tax liabilities, identify exemptions, and file estate tax returns for heirs — especially for estates with complex asset compositions.

Capital Gains Tax Advisory

We advise on CGT implications for real property transactions, ensuring proper computation and minimizing legitimate tax exposure.

Corporate Income Tax Advisory

We review your corporate tax position, identify planning opportunities within legal bounds, and ensure full BIR compliance.

Tax Compliance Review

We conduct tax health checks before BIR audits, identifying and correcting potential issues before examiners find them.

The QSP Difference

Why a CPA-Lawyer Wins More BIR Disputes

The BIR's assessors are accountants. They build cases using accounting entries, reconciliation schedules, and financial ratios. Challenging them requires someone who speaks the same language — and can demolish their computations with equal accounting fluency.

  • Reads your trial balance and identifies overassessments
  • Prepares Schedule of Disputed Items with full workings
  • Argues both legal defects AND accounting errors
  • Coordinates with your external auditors
  • Files pleadings with proper financial annexes
  • Negotiates compromise settlements with BIR

Legal + Accounting = Stronger Defense

Our partners have defended BIR assessments worth tens of millions of pesos. We attack assessments from both angles — the legal authority behind them and the mathematical accuracy of the figures.

Book a Tax Consultation — ₱1,000
Common Questions

Tax Law FAQ

A Letter of Authority authorizes BIR revenue officers to examine your books of accounts for a specific taxable year. Do not ignore it — you must acknowledge receipt. You may request a 30-day extension to gather your documents. Most importantly, engage a CPA-Lawyer before allowing the audit to proceed, as your document submissions and responses will form the basis of any future assessment. The earlier you get counsel, the more you can control the scope and outcome of the audit.

After completing an audit, the BIR issues a PAN detailing alleged tax deficiencies. You have 15 days from receipt to file a written response disputing the assessment. Failure to respond allows the BIR to issue a Final Assessment Notice (FAN) without further discussion. Your response to the PAN is your first and most critical line of defense — an experienced CPA-Lawyer can often significantly reduce or eliminate the assessed amount at this stage before the case escalates.

You have 30 days from receipt of the FAN to file a written protest — either a request for reconsideration (based on existing evidence) or a request for reinvestigation (submitting new evidence). If the BIR denies your protest, you can appeal to the Court of Tax Appeals (CTA) within 30 days of the denial. Missing these deadlines is fatal — the assessment becomes final and executory, and BIR can collect through distraint and levy.

BIR audits are fundamentally accounting exercises. The BIR builds its case using accounting entries, financial ratios, and reconciliation schedules. A CPA-Lawyer understands both the accounting issues driving the assessment (input-output VAT matching, withholding tax computations, income recognition) AND the legal arguments needed to challenge them. At QSP, all partners hold both CPA and law licenses — we attack assessments from both directions simultaneously.

The BIR has 3 years from the date of filing (or deadline for filing, whichever is later) to issue a tax assessment under ordinary circumstances. If a taxpayer filed a fraudulent return or failed to file, the period extends to 10 years from the discovery of fraud. This is why timely, accurate filing is critical — it starts the prescriptive clock running. After the period lapses, the BIR can no longer assess even if there were genuine deficiencies.

Yes. The BIR has the extraordinary power to enforce tax collections through administrative remedies — including warrants of distraint (seizing personal property or bank accounts) and levy (seizing real property) — without going to court first. This is why resolving BIR assessments through the protest and appeal process is critical. Once enforcement begins, the taxpayer's options become far more limited and expensive. Act early.

Received a BIR notice? Time is critical.

Our CPA-Lawyers respond to BIR LOAs, protests, and assessments. The earlier you act, the more options you have.

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