Immediate Suspension of All BIR Audit and Field Operations
(Revenue Memorandum Circular No. 107-2025 issued on November 24, 2025)
This Tax Alert is issued to inform taxpayers regarding the immediate suspension of all audit and other field operations of the Bureau of Internal Revenue (BIR) until further notice, as ordered by the Commissioner of Internal Revenue through Revenue Memorandum Circular (RMC) No. 107-2025.
Background and Rationale
In view of numerous complaints from taxpayers, stakeholders, and internal units regarding irregularities and inconsistencies, and to protect the integrity of audit operations, BIR will conduct a comprehensive review of existing policies and procedures of the BIR’s audit system.
Thus, to prevent exposure to potential abuse and operational weaknesses and to strengthen the credibility and defensibility of the BIR’s audit process, all audit and other field operations of the Bureau of Internal Revenue (BIR) are suspended effective immediately.
Coverage
Except for the listed exceptions, all ongoing field audits and related field operations, such as issuing LOA, Mission Orders (MO), examination, and verification of taxpayers’ books of accounts, records, and other related transactions, are suspended until the order is lifted by the Commissioner. No revalidation, extension, or supplementary LOA/MO will be issued also during the suspension, except for the listed exceptions.
The suspension applies to all BIR operating offices that conduct field audits and related field operations, including but not limited to:
- Large Taxpayers Service (LTS)
- Revenue Regions (RRs)
- Revenue District Offices (RDOs)
- National and Regional Investigation Divisions
- Assessment Divisions
- VAT Audit Unit (LTS)
- VAT Audit Sections
- Office Audit Sections
- All other offices, committees, and task forces authorized to conduct examinations, verification of taxpayers’ books of account, records, and other related transactions or investigations.
Nonetheless, taxpayers may voluntarily pay their known deficiency taxes without needing approval from the appropriate revenue officials.
Exceptions
Issuance of Assessment Notices, Warrants, and Seizure Notices shall continue under the following exceptions:
- Investigations of cases prescribing within six (6) months from the date of the Order;
- Processing/verification of estate, donor’s, capital gains, and withholding tax returns on the sale of real properties or shares of stocks, together with the related documentary stamp tax (DST) return related thereto;
- Examination or verification of internal revenue tax liabilities of taxpayers retiring from business
- 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;
- Claims for refund requiring issuance of LOA; and
- Other matters with deadlines or specific Commissioner orders
All BIR offices must submit an inventory of pending, unserved, or expired LOAs/MOs within 15 working days from the effectivity of the Order. A Technical Working Group will review and recommend reforms for LOA integrity and audit standards.
Non-compliance shall constitute an administrative offense and shall be subject to disciplinary action, without prejudice to applicable civil or criminal liability.