Summary
RMC No. 82-2022 clarifies the service of the electronic Letter of Authority (eLA) after RAMO No. 1-2020 deleted the 30-day service period in RAMO No. 1-2000.
CollapseExpand
Key points
- What changed. RAMO No. 1-2000 was amended by RAMO No. 1-2020, which deleted the provision in Item No. VIII 2.3. The timeline for service of the eLA is no longer stated.
- Duty to serve immediately. Revenue Officers must serve the eLA immediately upon issuance or assignment. The whole audit must finish within 180 days for RDO cases and 240 days for LT cases from the date the eLA is issued.
- Sanction. Not observing that timeline is gross neglect of duty, a grave offense subject to administrative sanctions under RMO No. 53-2010.
- Late service remains valid. The deleted 30-day period is no excuse for a Revenue Officer to delay service or for a taxpayer to refuse service or question validity. An eLA unserved at the Circular’s effectivity, or served beyond 30 days from issuance, stays valid and enforceable if the 180-day or 240-day period has not expired.
Who is affected
- Revenue Officers
- Taxpayers served with an eLA
Deadlines and effectivity
- Audit completion: 180 days for RDO cases, 240 days for LT cases from eLA issuance
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.