The Bureau of Internal Revenue (BIR) has issued a crucial clarification on its sweeping suspension of field audit operations across the Philippines. Through Revenue Memorandum Circular (RMC) 109-2025, released on December 23, 2025, the tax agency detailed the scope of the halt initially ordered under RMC 107-2025, which became effective on November 24, 2025.
What the Audit Suspension Covers
This directive orders a nationwide pause on all field audits, investigations, and similar operations until the BIR provides further notice. As part of this freeze, the bureau will temporarily stop issuing Letters of Authority (LOAs), Mission Orders (MOs), and all other official notices that initiate tax examinations. The primary goals of this unprecedented move are to safeguard taxpayer rights, resolve systemic issues within the audit process, and create a more transparent and standardized framework for future reviews.
The order is comprehensive, applying to all BIR offices. This includes every Revenue District Office (RDO), the Large Taxpayers Service (LTS), and all specialized audit units. The suspension is a significant shift in the BIR's standard operational procedure.
Key Exceptions to the Rule
While broad, the suspension is not absolute. The BIR has outlined several critical exceptions where audit activities will continue. These specific cases are:
- Cases where the right of the government to assess taxes will prescribe or expire within six months from November 24, 2025.
- The processing and verification of One-Time Transaction (ONETT) cases. This covers estate tax, donor's tax, and capital gains tax returns, as well as withholding tax and documentary stamp tax returns related to property and stock sales.
- Examination of the tax liabilities of taxpayers who are retiring from business.
- LOAs or MOs required for active criminal probes, such as tax evasion cases, initiated through verified intelligence, inter-agency referrals, or clear risk-scoring anomalies that demand immediate action to protect the government's case.
- Claims for tax refund where the law explicitly requires the issuance of an LOA.
- Other matters where strict deadlines are imposed or under the direct orders of the Commissioner of Internal Revenue (CIR).
Implications for Filipino Taxpayers
For the majority of taxpayers, this means a temporary reprieve from the stress of field audits. If you have an ongoing audit, you can expect a pause in field visits and examiner activities, unless your situation falls under one of the exceptions listed above.
However, it is vital to understand that all regular tax compliance obligations remain in full effect. The suspension does not mean a holiday from filing tax returns or paying taxes. Transactions like updating registration details, requesting certificates, or voluntarily settling known tax deficiencies must proceed as usual.
Taxpayers who wish to settle any identified deficiencies can still do so by using BIR Form 0605. Payments can be made through the authorized channels: the Electronic Filing and Payment System (eFPS), accredited agent banks, and other electronic payment gateways.
The BIR has stated that this audit suspension will remain in effect until it issues a new circular lifting the order. All taxpayers and practitioners are advised to be guided accordingly and to continue monitoring official BIR announcements for updates.
