Philippines: Tax alert - BIR commissioner suspends field audits, related field operations, LOA and MO issuances

27 Nov 2025    2 minute read

In brief

Effective 24 November 2025, the Commissioner of Internal Revenue (CIR) has ordered the immediate suspension of all ongoing field audits and related field operations through Revenue Memorandum Circular No. 107-2025 ("RMC 107-2025"). This covers the issuance of Letters of Authority (LOA), Mission Orders (MO), examinations, and verification of taxpayers’ books of accounts, records and other related transactions. The suspension will remain in effect until the CIR issues another order.

Contents

In more detail

The suspension order applies to all operating offices of the BIR that conduct field audits and related field operations, including but not limited to the following:

  1. Large Taxpayers Service (LTS)
  2. Revenue Regions (RRs)
  3. Revenue District Offices (RDOs)
  4. National and Regional Investigation Divisions
  5. Assessment Divisions
  6. VAT Audit Units
  7. VAT Audit Sections
  8. Office Audit Sections
  9. All other offices, committees and task forces authorized to conduct examinations, verification of taxpayers’ books of account, records, and other related transactions or investigations

The issuance of written orders to audit or investigate taxpayers’ internal revenue liabilities is suspended, except in the following circumstances:

  1. Investigation of cases prescribing within six months from 24 November 2025
  2. Processing and verification of estate tax returns, donor’s tax returns, capital gains tax returns, and withholding tax returns on the sale of real properties or shares of stocks, together with the documentary stamp tax returns related thereto
  3. Examination or verification of internal revenue tax liabilities of taxpayers retiring from business
  4. LOAs/MOs necessary for active criminal probes conducted by duly authorized enforcement units through verified intelligence reports, inter-agency referrals, third-party data validation, or risk-scoring anomalies that require immediate audit action where delay would prejudice the government’s case
  5. Claims for refund where the issuance of an LOA is statutorily required
  6. Other matters/concerns where deadlines have been imposed or under the orders of the CIR

RMC 107-2025 further clarifies that no revalidation, extension, replacement or supplementary LOA and MO shall be issued during the suspension period unless it falls under the exceptions.

Despite the suspension, taxpayers may voluntarily pay their known deficiency taxes without needing approval from the appropriate revenue officials.

During the suspension period, the Technical Working Group/Review Committee on LOA Integrity and Audit Reforms will review current policies and develop a new LOA issuance protocol focused on integrity, incorporating digital safeguards and standardized audit practices.

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Quisumbing Torres, Manila
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