The Bureau of Internal Revenue (BIR) has released Revenue Memorandum Circular (RMC) No. 109-2025 to clarify the scope of the audit suspension announced under RMC No. 107-2025, which took effect on November 24, 2025. This suspension halts all field audits and related operations nationwide until further notice.
Under the directive, the BIR will temporarily stop issuing Letters of Authority (LOAs), Mission Orders (MOs), and other notices related to tax examinations. The move aims to protect taxpayer rights, address systemic audit issues, and develop a transparent, standardised audit framework.
The suspension applies to all BIR offices, including Revenue District Offices, Large Taxpayers Service, and specialised audit units. However, certain cases remain exempt:
a. Cases prescribing within six (6) months from November 24, 2025;
b. Processing and verification of One-Time Transactions (ONETT) cases such as estate tax returns, donor’s tax returns, capital gains tax returns, and withholding tax returns on sale of real and personal properties, shares of stocks, together with the documentary stamp tax returns;
c. Examination or verification of internal revenue tax liabilities of taxpayers retiring from business;
d. Letter of Authority/Mission Orders needed for active criminal probes conducted by duly authorised 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 (Tax evasion cases);
e. Claims for refund where the issuance of a LOA is statutorily required; and
f. Other matters/concerns where deadlines have been imposed or under the orders of the CIR
What this means for taxpayers
- No field audits for now: Taxpayers with ongoing audits can expect a pause in field visits and examinations unless their case falls under the listed exceptions.
- ·Compliance obligations remain: Filing and payment of taxes continue as usual. The suspension does not affect regular transactions like registration updates, certification requests, or voluntary settlements of deficiency taxes.
Taxpayers who wish to settle known deficiencies may do so using BIR Form 0605. Payments can be made through the Electronic Filing and Payment System (eFPS) or via authorised banks and electronic payment gateways.
The suspension will stay in effect until further notice from the BIR.
Please be guided accordingly.
Source:
P&A Grant Thornton
Certified Public Accountants
P&A Grant Thornton is the Philippine member firm of Grant Thornton International Ltd
As published in SunStar Cebu, dated 18 December 2025
