Padilla, R. M. (2014). Revisiting the policy of the BIR in implementing the requirement of the DOF for importers and customs brokers to secure BIR clearance certificate prior to BOC accreditation (Unpublished master's thesis). Public Management Development Program, Development Academy of the Philippines.

Public Management Development Program Senior Executive Class Batch 3 Thesis (SEC)--Development Academy of the Philippines.

In order to purge sham entities that are being used as fronts by smugglers, Department Order No. 12-2014 issued by the Secretary of Finance requiring importers and customs brokers to secure an Importer's Clearance Certificate and Broker's Clearance Certificate as part of a two-phase process for their accreditation. Pursuant to said Department Order, the BIR issued Revenue Memorandum Order (RMO) 10-2014, prescribing the policies, guidelines and procedures in the accreditation of importers and customs brokers, and the revocation thereof. The function of accrediting importers and customs brokers was transferred to the BIR from the BOc's Interim Customs Accreditation Unit in line with the reorganization of the functions of the two agencies. This will allow the BIR to track down smuggled goods that end up being sold to the market without proper payment of corresponding taxes. To implement RMO 10-2014, the function was lodged to the Accounts Receivable Monitoring Division (ARMD) of the BIR, a Division which, among other functions, is in charge of issuing Tax Clearance Certificates. The RMO requires that unless otherwise exempted, all importers and customs brokers are required to secure accreditation from the BIR through the ARMD which will evaluate and approve/deny the application based on submission of required documents and compliance with all the criteria set forth in the RMO. Problems arose in the ARMD's capacity to process the application and in the difficulty of the customs brokers and importers to comply with the documentary requirements, creating delay in the resolution of the application. This paper will tackle the problems faced by the stakeholders: the ARMD, importers and, customs brokers, along with the trade-offs between meeting the objectives of getting rid of sham entities and cooption against the stringent requirements for accreditation. The following alternatives along with the status quo, were analyzed according to the four main constraints which bear on the objective of designing a policy that will work as intended, as identified by Bardach: decentralization of application, computerization of application and process and, creation of a new Division. This leads the author to recommend computerization of the application and its processing. This will entail the least inconvenience and appears to be acceptable to all stakeholders and will reduce the time for processing and possible face to face contacts that give opportunity for corruption.