Tax Alert No. 34 Revenue Memorandum Circular (RMC) No. 107-2025

Suspension of all Audit and Other Field Operations of the Bureau of Internal Revenue Until Lifted by the Commissioner of Internal Revenue 

Please be informed that RMC No. 107-2025 has been issued by the BIR on 24 November 2025 ordering the suspension of all audit and field operations nationwide until further notice.    

Effective immediately, all ongoing field audits and related operations are suspended until such time that the Commissioner lifts the suspension. The activities covered include:  

1. Issuance of Letters of Authority (LOAs) and Mission Orders (MOs);   
2. Examinations and verification of taxpayers’ books of accounts, records, and other related transactions;  
3. Revalidation, extension, replacement, or issuance of supplementary LOAs and MOs, except as provided under the enumerated exceptions below; and  
4. Issuance of assessment notices, warrants, seizure notices unless falling under the stated exceptions. 

Taxpayers may still voluntarily settle their known deficiency taxes without prior approval from the concerned revenue officials.   

BIR offices covered by the suspension 

The suspension applies to all BIR operating offices engaged in field audits and related field operations, including the Large Taxpayers Service (LTS), Revenue Regions (RRs), Revenue District Offices (RDOs), Assessment Divisions, National and Regional Investigation Divisions, as well as other offices or task forces conducting examinations, investigations, and other related transactions.  

Exceptions from suspension 

The BIR will continue to issue written orders for audits or investigations, as well as Assessment Notices, Warrants, and Seizure Notices, in relation to the following taxpayers or situations:   

1. Cases set to prescribe within six (6) months from the date of the RMC (i.e., until 24 May 2026);  
2. Processing and verification of tax returns on the sale of real properties or shares of stocks (i.e., estate tax, donor’s tax, documentary stamp tax, capital gains tax, and withholding tax);  
3. Examination or verification of internal revenue tax liabilities of taxpayers retiring from business;  
4. 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;  
5. Claims for refund where the issuance of a LOA is statutorily required; and  
6. Other matters/concerns where deadlines have been imposed or under the orders of the Commissioner.  

You may access the full version of the RMC through the BIR website.    

(PwC Note: The RMC did not expressly include the issuance of the Final Decision on Disputed Assessment [FDDA] in the suspension. Thus, the BIR may be expected to continue to issue FDDAs for assessments for which a Final Assessment Notice [FAN] has been issued.)

For any inquiry or request for assistance, please feel free to contact anyone from our Tax Services group. You may also reach us through this link