RMO No. 01-2024: Further amends Revenue Memorandum Order No. 6-2023 prescribing the updated and consolidated policies, guidelines and procedures for BIR audit program

Summary

RMO No. 01-2024 further amends RMO No. 6-2023 on the BIR audit program, changing the eLA coverage, the audit time frame and the handling of cases after a taxpayer transfers registration or is enlisted or delisted as a large taxpayer.

Key points

1. Mandatory eLA cases. Item III.A.1 now includes audit of taxpayers who failed at least three (3) times in any given period to pay or remit taxes due shown in returns filed through eFPS, or who later filed amended returns showing a decrease or no tax due.
2. Time frame for reports. Under Item IV.C.6, eLAs other than replacement eLA have 180 days for Regional cases, 240 days for LT cases, 120 days for OAS and 90 days for LTVAU and VATAS, counted from the date of the eLA.
3. Suspension of day count. Counting is suspended when the Revenue Officer requests a Subpoena Duces Tecum (SDT) or an Exchange of Information (EOI). Suspension starts when the concerned office receives the request and is lifted when the reply is forwarded to the requesting RO.
4. SDT issuance. The procedure under Item III.3.5 of RMO No. 10-2013, as amended by RMO No. 8-2014, of issuing an SDT within two (2) working days from receipt of request must be strictly observed.
5. Transferred or re-classified taxpayers. Under amended Item IV.G.2.b, the old handling BIR Office continues audits begun before the transfer or enlistment or delisting, and handles protests against assessment notices. Unprotested assessments that became delinquent accounts go to the new office, which issues all later eLAs and TVNs.

Who is affected

• Taxpayers who repeatedly failed to pay or remit taxes shown in eFPS returns
• Transferred or newly enlisted or delisted large taxpayers
• BIR Revenue Officers

Deadlines and effectivity

• Audit report time frames run from the date of the eLA
• SDT issuance within two (2) working days from receipt of request

Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.