RECENTLY, the Bureau of Internal Revenue (BIR) issued Revenue Regulations 11-2023 (the Regulation) dated Sept. 14, 2023, which prescribes the use of email and electronic signature as an additional mode of service of Warrants of Garnishment (WGs). The Regulation provides that, starting Oct. 1, 2023, the Revenue Officers may serve WGs via email to depository banks, thereby initiating the collection process without the need for personal service. Furthermore, the Regulation requires bank head offices and branches to provide their official email addresses to the BIR office where they are registered.

In issuing the Regulation, the BIR cited Section 208 in relation to Section 244 of the National Internal Revenue Code of 1997, as amended (Tax Code), regarding the authority of the Commissioner of Internal Revenue (CIR) to enforce collection of delinquent internal revenue tax liabilities. It also took into account Republic Act (RA) 8792, or the 'Electronic Commerce Act of 2000,' the Rules on Electronic Evidence, as well as the 2019 Amendments to the 1997 Rules of Civil Procedure, for the use of email and electronic signature as an additional mode of service of WGs.