The bureau has amended the Section 2 of RR No. 10-2010 under the new Revenue Regulations No. 3-2014 as follows:
"A taxpayer shall be duly notified in writing by the Commissioner that a foreign tax authority is requesting for exchange of information held by financial institutions pursuant to an international convention or agreement on tax matter within sixty (60) days from receipt of the said request.
However, if notification within this period will undermine the chances of success of the investigation conducted by the requesting foreign tax authority, the taxpayer shall notified by the requesting foreign tax authority, the taxpayer shall notified within six (6) calendar months from receipt of the request."
Please refer ftp://ftp.bir.gov.ph/webadmin1/pdf/82785RR%20No%20%203-2014.pdf of the full tex of the revenue regulations.
