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Duterte has been criticized for setting aside the Arbitral Award invalidating China’s massive claims in the South China Sea in pursuit of warmer relations with China.

The President has repeatedly said that Philippines cannot win a war with China because it will only result in a massacre of Filipino soldiers.

If the BIR is not convinced by the taxpayer’s argument, it will proceed with the issuance of a Preliminary Assessment Notice (PAN).

The taxpayer will have 15 days to respond to the PAN, and only after the said period prescribes can the BIR issue the Formal Letter of Demand (FLD) and the Final Assessment Notice (FAN). 8745), the foregoing documents were received by persons not authorized by the taxpayer.

The SC justice noted that prior to Duterte’s pronouncement in his interview with Pastor Apollo Quiboloy, there was still a debate in the government on whether the verbal fishing deal was legally binding.

Earlier, the President said he might use his fourth State of the Nation Address on July 22 to “educate” his critics on his verbal fishing deal with Chinese President Xi Jinping.

But Carpio advised the President not to tackle in his SONA the matter of the fishing deal with China because it will make the verbal agreement binding to the Philippine government.

The LOA will contain which documents need to be submitted to the BIR.

Failure to provide the requested documents will subject the taxpayer to the issuance of Subpoena Duces Tecum.

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