Deficiency interest and delinquency interest on unpaid taxes — no more double imposition

SECTION 249 of the National Internal Revenue Code, as amended (Tax Code), provides for deficiency interest and delinquency interest, which may be assessed and collected on any unpaid amount of tax.

Deficiency interest is assessed and collected from the date prescribed for payment until the amount is fully paid or upon the issuance of a notice and demand by the Commissioner of Internal Revenue (CIR), whichever comes earlier. On the other hand, delinquency interest is assessed and collected in case of failure to pay the following on the due date appearing in the notice and demand of the CIR: (1) the amount of the tax due on any return required to be filed; (2) the amount of the tax due for which no return is required.