16/12/2025
The Bureau of Internal Revenue has recently issued Revenue Memorandum Circular (RMC) No. 109-2025 clarifying the scope of the audit suspension under RMC No. 107-2025. Key takeaways are as follows:
1. Scope of Suspension: Suspends all field audits, investigation, and operations, including the service of Letters of Authority (LOAs), Mission Orders (MOs), and Tax Verification Notices (TVNs) by all investigating offices (LTS, RDOs, etc.). It also covers the issuance of Subpoena Duces Tecum (SDTs) necessary for these audits.
2. Critical Exceptions: Audits and investigations shall proceed for:
• Cases prescribing within 6 months from Nov 24, 2025
• Tax fraud/evasion cases with verified intelligence or risk scoring
• One-Time Transactions (ONETT) and withholding on property sales
• Retiring/closing businesses
• Claims for refund
3. Collection and Enforcement: The suspension does not stop the collection process.
• Warrants of Distraint/Levy/Garnishment and Seizure Notices for final and executory assessments will continue.
• Letters to third parties (e.g., Register of Deeds) for property verification are allowed.
4. Assessments: PANs, FANs, and FDDAs may still be issued for cases falling under the exceptions (e.g., prescribing cases). For other pending cases, taxpayers may still reply, protest, or submit documents for reinvestigation.
5. Voluntary Settlement: Taxpayers may voluntarily settle deficiency taxes using BIR Form 0605 without prior approval from a Revenue Officers/Officials.
Source: BIR website
