TAX COMPLIANCE BULLETINS

Revenue Memorandum Circular (RMC) No. 109-2025 was issued to provide crucial clarification on the exact coverage of the audit suspension mandated by RMC No. 

107-2025. This circular distinguishes between the activities that must pause and the critical functions that must continue.

Activities That Remain SUSPENDED (The Audit Pause):

The general suspension applies to fieldwork and activities involving direct contact with taxpayers concerning general tax audits:

• Issuance/Service of New LOAs and MOs: The serving or issuance of new Letters of Authority (LOAs) and Mission Orders (MOs) for general tax audits is halted.
• On-site  Examinations and Fieldwork: Physical verification of taxpayer books, records, and related on-site visits are temporarily stopped.
• Issuance of Subpoena Duces Tecum: The issuance of subpoenas related to any audit or operation covered by the general suspension is also paused.

Activities That Are NOT Suspended (The Critical Exceptions):

RMC No. 109-2025 explicitly outlines the critical exceptions where examinations and processes must continue:

• Audit  of Prescribing Cases: Audits for tax cases that are set to prescribe (expire) within six (6) months from the date of the RMC must proceed to prevent revenue loss due to the running of the Statute of Limitations.
• One-Time Transactions (ONETT): The processing, verification, and assessment of returns related to key One-Time Transactions continue, specifically:
  • Estate Tax
  • Donor's Tax
  • Capital Gains Tax (CGT)
  • Documentary Stamp Tax (DST) on transfers of properties.
• Retiring Businesses: Examination and processing related to taxpayers who are in the process of retiring or closing their business operations must continue.
• Active Criminal Probes: Audits, LOAs, or MOs related to criminal tax fraud investigations that are based on verified intelligence can proceed.
• Assessment and Collection Deadlines: The statutory periods for the BIR to issue Preliminary Assessment Notices (PAN), Final Assessment Notices (FAN), Warrants of Distraint and/or Levy, and other collection actions for non-suspended cases remain in effect. Taxpayers must also continue to meet their deadlines for filing protests and replies.
• Voluntary Payments: Taxpayers are still permitted to voluntarily pay known deficiency taxes, even without receiving an official assessment.

RMC No. 109-2025 ensures that the BIR's necessary "Audit Reset" for reform does not compromise time-sensitive government functions. It provides a strategic balance, protecting taxpayer rights while securing the collection of critical and expiring tax revenues.

Reference: RMC No. 109-2025, Clarification on the Coverage of Audit Suspension Under RMC No. 107-2025  RMC No. 109-2025.pdf 

Disclaimer: This article is for general informational purposes only and should not be taken as professional tax, accounting, or legal advice. Readers are encouraged to consult the official text of RMC No. 109-2025 and seek guidance from qualified tax professionals for compliance matters specific to their circumstances. 

As part of the Philippines’ continuing commitment to financial integrity and international compliance, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular No. 86-2025 to formally support the implementation of the National Anti-Money Laundering, Counter-Terrorism Financing, and Counter-Proliferation Financing Strategy (2023–2027). This circular affirms the BIR’s institutional role in the country’s whole-of-government approach to combating financial crimes and reinforces its alignment with the standards set by the Financial Action Task Force (FATF). It also mandates active participation in the Money Laundering/Terrorism Financing National Risk Assessment (NRA), ensuring that tax enforcement contributes meaningfully to national security and regulatory cohere

RMC No. 86-2025 enjoins all BIR offices and personnel to support the implementation of the national AML/CFT/CPF strategy and participate in the NRA. The directive emphasizes the importance of inter-agency coordination, data sharing, and risk-based profiling to strengthen the country’s defenses against illicit financial flows.

The circular reflects the Philippines’ commitment to the FATF framework and positions the BIR as a key contributor to AML/CFT/CPF efforts. It calls for the integration of financial intelligence into tax administration and promotes proactive supervision across sectors vulnerable to money laundering, terrorism financing, and proliferation financing.

BIR offices are directed to:

• Participate in the National Risk Assessment (NRA) through data sharing, profiling, and analysis
• Embed AML/CFT/CPF objectives into audit procedures, internal controls, and enforcement protocols
• Coordinate with the Anti-Money Laundering Council (AMLC) to support national implementation and regulatory harmonization

These responsibilities signal a shift toward integrated compliance and cross-sector vigilance.

Although the circular is addressed to internal BIR personnel, it carries indirect implications for regulated entities and taxpayers. These may include:

• Enhanced scrutiny of financial records and tax filings
• Greater emphasis on beneficial ownership transparency
• Potential updates to registration and reporting protocols aligned with AML/CFT/CPF standards

Entities engaged in cross-border trade, digital commerce, or high-risk sectors should ensure documentation is complete, traceable, and defensible.

For professionals in governance, audit, and risk management, RMC No. 86-2025 signals a broader regulatory posture:

• Expanded audit scope and taxpayer profiling based on AML/CFT/CPF risk indicators
• Increased inter-agency data sharing and enforcement coordination
• Heightened emphasis on transparency, traceability, and defensible documentation

This issuance reinforces the need for integrated risk management frameworks across both public and private institutions.

RMC No. 86-2025 positions the BIR as a strategic partner in the Philippines’ national effort to combat financial crimes. It strengthens inter-agency collaboration, enhances 

risk-based enforcement, and aligns tax administration with global AML/CFT/CPF standards. The circular underscores the importance of proactive compliance and institutional readiness for evolving regulatory expectations.

Access the full issuance via the BIR official website or consult your compliance advisor for implementation guidance or read the full disclosure here:  RMC No. 86.pdf 

The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular No. 005-2026 on January 12, 2026, formalizing the use of Chatbot REVIE as an official platform for verifying the authenticity of Letters of Authority (LOAs).

Purpose of the Circular

The issuance aims to:

• Enhance transparency in tax enforcement
• Protect taxpayers from unauthorized revenue officers
• Provide a reliable and secure method of confirming valid LOAs
• Maintain a single, official verification channel for taxpayers

LOA Verification Process

Under the circular, taxpayers may:

1. Access Chatbot REVIE through the BIR website (www.bir.gov.ph)
2. Select the LOA Verifier option
3. Input the following details as indicated in the LOA:
   • Taxpayer Identification Number (TIN)
   • Name of the Taxpayer
   • LOA Case Number

If the LOA is validated, the system will confirm that the LOA exists. If not found, the taxpayer is advised to coordinate with the BIR for further verification.

Practical Implications for Taxpayers

Taxpayers are encouraged to verify LOAs before accommodating any audit or examination, ensuring that only duly authorized BIR personnel conduct official transactions. This system strengthens taxpayer protection and promotes accountability within the tax administration process.

Reference:  https://bir-cdn.bir.gov.ph/BIR/pdf/RMC%20No.%205-2026.pdf

Disclaimer: This article is for general informational purposes only and should not be taken as professional tax, accounting, or legal advice. Readers are encouraged to consult the official text of Revenue Memorandum Circular No. 005-2026 and seek guidance from qualified tax professionals for compliance matters specific to their circumstances.

ABD/MP