The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular (RMC) No. 29-2023 last March 10, 2023, relative to RMC No. 98-2010 which prescribed the guidelines and procedures regarding unserved Letters of Notice, Letters of Authority and Tax Verification Notices concerning taxpayers which could not be located (CBL) in their registered addresses.

Said RMC reiterates the effect of CBL taxpayers which includes (a) non-deductibility of purchases with CBL taxpayers whether related to cost of sales or operating expenses, (b)Value Added Tax component cannot claim Input Value Added Tax if transaction has Value Added Tax component, and unless the buyer can prove the existence of the supplier tagged as CBL by the BIR and the authenticity of purchases made, these tax consequences shall apply to transactions that were made after the publication of the name of the CBL taxpayer.

Further, suspension of the running of the prescriptive period to assess under Section 203 of the National Internal Revenue Code, as amended, shall commence as soon as the handling Revenue Officer submits a report that the said taxpayer is considered as cannot be located and must be duly substantiated by the required documents, as publication of CBL taxpayers is not a pre-requisite thereof. Thereafter, the suspension of the prescriptive period already set in and is tagged in the system as suspended. 


Please be guided accordingly.



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 12 April 2023