𝗕𝗜𝗥 𝗛𝗢𝗦𝗧𝗦 𝗙𝗜𝗥𝗦𝗧 𝗣𝗘𝗠𝗡𝗔 𝗥𝗘𝗩𝗘𝗡𝗨𝗘 𝗖𝗢𝗠𝗠𝗨𝗡𝗜𝗧𝗬 𝗢𝗙 𝗣𝗥𝗔𝗖𝗧𝗜𝗖𝗘 𝗦𝗧𝗨𝗗𝗬 𝗩𝗜𝗦𝗜𝗧 𝗢𝗡 𝗧𝗔𝗫 𝗗𝗜𝗦𝗣𝗨𝗧𝗘 𝗥𝗘𝗦𝗢𝗟𝗨𝗧𝗜𝗢𝗡

The Bureau of Internal Revenue (BIR) hosted the 2026 Public Expenditure Management Network in Asia (PEMNA) Revenue Community of Practice (R-CoP) Study Visit at the BIR National Office on September 28–30, 2026. This marked the first Study Visit under the PEMNA Revenue Community of Practice since its launch in October 2025.

The event brought together a six-member delegation from the Kingdom of Cambodia, representatives of the PEMNA Secretariat, and an official from the Republic of Korea. Dr. Seng Cheaseth, Director of the Department of Law, Tax Policy and International Tax Cooperation (DLPIC) and Chair of the PEMNA R-CoP, led the Cambodian delegation, while the PEMNA Secretariat was represented by a team led by Mr. Lloyd Choi, Team Manager.

For the Study Visit, Cambodia selected the Philippines because of its two-level tax dispute resolution framework, which provides administrative and judicial remedies. Of particular interest was the Court of Tax Appeals (CTA), a specialized court handling tax cases.

In his keynote message, Commissioner Charlito Martin R. Mendoza underscored the importance of fair and credible mechanisms for resolving tax disputes in strengthening taxpayer trust and voluntary compliance. He emphasized that taxpayers should be able to question an assessment, while the government must be able to credibly justify its assessment and demand for payment, enforce the law, and collect what is properly due.

“The real question, therefore, is not whether disputes will arise, but how fairly, efficiently, and credibly we resolve them,” Commissioner Mendoza said.

He also encouraged the foreign delegates and their BIR counterparts to openly share their experiences in resolving tax disputes.

“We are your hosts for these three days, but we do not see this as a one-way exchange. We also want to learn from you,” he said.

Over the three-day program, BIR officials presented the Philippine tax dispute resolution framework, covering the assessment and administrative protest process under Section 228 of the National Internal Revenue Code of 1997, as amended, and its implementing regulations. Discussions also touched on compromise settlement and abatement of tax liabilities, the rules governing the Bureau’s decisions, and appeals to the Court of Tax Appeals.

The program included a dedicated CTA session covering its jurisdiction, structure, procedures for filing tax cases, and selected jurisprudence. The Cambodian and Korean delegates, in turn, shared their respective countries’ dispute resolution systems, challenges, and recent reforms, leading to an open exchange of practices and experiences. The Study Visit concluded on September 30, 2026, with a roundtable discussion on lessons learned, reinforcing continued collaboration and knowledge sharing within the PEMNA network toward more effective and equitable revenue administration in the region.

PEMNA is a regional network of public finance officials in Asia that promotes peer learning on public financial management through its communities of practice, including the Revenue, Budget, and Treasury communities.