BIR Audit Defense & Tax Assessment Lawyers in the Philippines
Receiving a Letter of Authority (LOA) from the Bureau of Internal Revenue is one of the most stressful events a business or individual can face.
An LOA is not just a routine notice it opens the door to a formal BIR audit that can result in significant tax assessments. At Aureada Law, our team of CPA-lawyers in the Philippines provides strategic defense from the moment you receive an LOA through final resolution whether through protest, compromise settlement, or litigation before the Court of Tax Appeals (CTA).
Our Core Expertise
We handle the full range of tax cases and compliance matters, including:
• Letters of Authority (LOA)
• Notices of Discrepancy (NOD)
• Preliminary Assessment Notices (PAN)
• Final Assessment Notices (FAN)
• Tax reconciliation and dispute resolution
• Filing protests against unwarranted assessments
• Negotiating compromise settlements
• Assisting with voluntary disclosures to minimize exposure
Strategic Tax Solutions
Our approach combines deep technical expertise with strategic foresight:
• Pre-audit tax health checks to identify and resolve issues before BIR audits.
• Optimizing deductions and exemptions under current Philippine tax laws.
• Structuring cross-border transactions to maximize treaty benefits and avoid double taxation.
• Tax-efficient corporate restructuring, mergers, and acquisitions planning.
• Negotiating with revenue authorities to achieve favorable settlements.
• Pursuing refunds or tax credits for overpaid taxes.
Representation and Litigation
We represent clients in:
• Administrative proceedings before the Bureau of Internal Revenue (BIR)
• Judicial proceedings before the Court of Tax Appeals (CTA)
• Appellate advocacy before the Supreme Court
At every stage, we ensure precise documentation, persuasive advocacy, and a robust defense strategy tailored to your case.
International and Specialized Tax Services
International tax planning and advisory
• Transfer pricing compliance and documentation
• Cross-border investment structuring for multinational operations
A Letter of Authority authorizes BIR examiners to examine your books of account and accounting records for a specified taxable year. If you receive an LOA, time is critical the BIR operates under strict timelines and your rights are best protected from day one.
Our CPA-lawyer team helps you:
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Review the LOA for validity scope, taxable year covered, authorized examiners
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Organize and prepare your accounting records before examiner interviews
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Respond to BIR requests for documents while protecting privileged communications
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Identify and document legitimate deductions to reduce your tax exposure
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Negotiate and request for reconsideration or reinvestigation at the assessment stage
Practical Reminder for Taxpayers
If your company receives a BIR LOA, avoid rushing into submissions without first understanding the scope and implications of the audit. A careful review of the LOA, your accounting records, and prior tax filings can help identify possible issues before they become formal findings.
Our firm helps taxpayers approach BIR audits with structure, documentation, and strategy so that responses are timely, accurate, and aligned with available legal remedies.