Summary
RMC No. 109-2025 clarifies the coverage of the audit suspension under RMC No. 107-2025, which took effect on November 24, 2025.
Key points
- Who and what is suspended. All taxpayers with ongoing audits or investigations under issued LOAs or MOs are covered, including individuals, corporations, estates, and business owners. Suspended activities include field audits, issuance of LOAs, MOs, and Tax Verification Notices, related notices, and subpoenas duces tecum needed for an audit. The Tax Mapping/Tax Compliance Verification Drive is also suspended.
- Exceptions stay. Audit continues for the Section IV cases of RMC No. 107-2025, such as cases prescribing within six (6) months, ONETT cases, retiring or closing taxpayers, criminal tax investigations, refund claims requiring an LOA, and matters with deadlines set by the Commissioner. Cases prescribing within six (6) months need their investigation reports submitted three (3) months before the prescription date.
- Retirement or closure. Tax clearance requests involving gross sales or receipts exceeding ₱1,000,000.00 or gross assets exceeding ₱3,000,000.00 are subject to mandatory audit.
- Assessment and collection. Assessment Notices may be issued only in Section IV cases. Collection actions on final and executory assessments, such as Warrants of Distraint/Levy, Garnishment, Seizure Notices, and Collection Letters, continue. Reminder letters on information returns are also not suspended.
- Payments and filing. Taxpayers may voluntarily settle known deficiency taxes without prior approval, using BIR Form No. 0605. Settlements agreed before the suspension may proceed if supported by Agreement Form QF-06-01-2024 signed before the RMC took effect. Filing of returns and payment of taxes continue normally.
- Scope and duration. The suspension applies nationwide to all investigating offices. It stays until the Commissioner issues an order lifting it, and offices must submit the inventory of LOAs and MOs within fifteen (15) working days of the effective date.
Who is affected
- All taxpayers with ongoing audits or investigations under LOAs or MOs
- All BIR operating offices that conduct field audits
Deadlines and effectivity
- RMC No. 107-2025 effective: November 24, 2025
- Issued: December 12, 2025
- Inventory due: within 15 working days of the effective date
Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.
Copies of BIR issuances are hosted here for reference. For the official version, check bir.gov.ph. Summaries by Tax Resources PH are not a substitute for the full text or professional advice.