RMO No. 36-2025: Further Amending Revenue Memorandum Order No. 6-2023, Prescribing the Updated and Consolidated Policies, Guidelines and Procedures for BIR Audit Program

Key points

1. New mandatory eLA cases. Items 1.7 to 1.10 are listed: taxpayers with VAT returns showing erroneous input tax carry-over (ITCO); taxpayers with a Mission Order whose findings show understatement of sales by 30% or more and unreliable accounting records; non-compliance arising from Spontaneous Exchange of Information (SEOI); and policy cases or industry issues directed by the Commissioner (MCIR).
2. Termination Letter. For taxpayers retiring or undergoing merger, consolidation, split-up, spin-off or other reorganization under mandatory audit, a Termination Letter is prepared for paid cases or cases with no findings. The Assessment Division of the Regional Office or the concerned Large Taxpayers Audit Division of the LTS prepares it after the audit report is approved by the Regional Director or Assistant Commissioner-LTS.
3. RDO copy and tax clearance. For certain regional cases, the Assessment Division gives the RDO a copy of the letter and the approved memorandum report recommending closure or cessation of business registration. The Tax Clearance Certificate of Liabilities is issued only upon full settlement of deficiency assessments.
4. ITCO audits. The VAT Audit Section (VATAS) of the Assessment Division audits mandatory ITCO cases. Where VATAS is not yet institutionalized, the RDO with jurisdiction over the registration conducts the audit.

Who is affected

• Taxpayers with erroneous input tax carry-over
• Taxpayers retiring from business or undergoing reorganization
• Assessment Divisions, Large Taxpayers Audit Divisions and RDOs

Deadlines and effectivity

• Issued August 18, 2025