IN the recent case Integrated Bar of the Philippines v. Purisima (GR 211772 and 212178, April 18, 2023), the Supreme Court invalidated portions of Sections 2(1) and 2(2) of Bureau of Internal Revenue (BIR) Revenue Regulations (RR) 4-2014 or the 'Guidelines and Policies for the Monitoring of Service Fees of Professionals' for violating the right to privacy of the professionals and their clients.

RR 4-2014 required all self-employed professionals to (1) submit to the BIR an affidavit of rates, manner of billing, and the factors that they consider in determining service fees; (2) register with the BIR the books of accounts and appointment books containing the names of their clients, and their meeting date and time; and (3) issue a receipt registered with the BIR showing 100 percent discount if no professional fees are charged.