Tax Alert No. 35 [Revenue Memorandum Circular (RMC) No. 52-2021 dated 14 April 2021]

Suspension of the running of the Statute of Limitations on assessment and collection of taxes pursuant to Section 223 of the National Internal Revenue Code (NIRC) due to the declaration of Enhanced Community Quarantine (ECQ) in NCR Plus, and other applicable jurisdictions

The Commissioner of Internal Revenue has issued RMC No. 52-2021 dated 14 April 2021 to suspend of the running of the Statute of Limitations on assessment and collection of taxes in light of the declaration of ECQ in Metro Manila, Bulacan, Cavite, Laguna, and Rizal, collectively known as NCR Plus bubble from 29 March 2021 to 11 April 2021.

Pursuant to Section 223 of the NIRC of 1997, as amended, the running of the statute of limitations for assessment and collection of deficiency taxes is suspended in the affected jurisdictions while the ECQ is in effect, including any extension/s thereof, and for sixty (60) days thereafter. The suspension of the running of the Statute of Limitations shall apply with respect to the issuance and service of assessment notices, warrants and enforcement, and/or collection of deficiency taxes.

This RMC shall apply nationwide to areas placed under ECQ.