Tax Alert No. 9 [Revenue Memorandum Order (RMO) No. 06-2026 dated 04 March 2026]

09 Mar 2026

Amendments and Supplemental Guidelines Governing the Implementation of Revenue Memorandum Order (RMO) No. 1-2026

Please be informed that Revenue Memorandum Order No. 006-2026 has been issued on 04 March 2026 to prescribe amendments, supplemental procedure, and clarificatory guidelines to RMO No. 01-2026, following certain concerns and implementation matters raised after issuance thereof. The following amendments in RMO No. 01-2026 are laid down below:

I. The following dates in RMO No. 1-2026 are amended:

Event	From	To
Deadline for filing written Requests for Non-Consolidation of VAT Audit Cases	16 February 2026	March 13, 2026
Automatic consolidation of all pending eLAs except where a written Request for Non-Consolidation is duly filed	04 March 2026	20 March 2026
Last day of audit operations for VAT Audit Sections (VATAS) and Large Taxpayers VAT Audit Unit (LTVAU)	30 April 2026	15 May 2026
Automatic consolidation of all pending eLAs which were previously allowed to proceed separately pursuant to a Request for Non-Consolidation	04 May 2026	18 May 2026
Last day of VATAS and LTVAU for purposes of winding up its operations	15 May 2026	29 May 2026

II. Annex "A" of RMO No. 1-2026

Item No. 7 under l. Mandatory Case*, a. To be covered by Electronic Letter of Authority (eLA) shall now read as follows:

Selection Criteria

Selection Code

xxx xxx xxx

7. Taxpayers requesting for tax clearance whose gross sales of the immediately preceding year exceed Three Million Pesos (P3, 000, 000.00) or whose gross assets upon retirement exceed Eight Million Pesos (P8.000.000.00), due to:

Death of the taxpayer;
Taxpayers retiring from business: or
Taxpayers undergoing merger/consolidation/split-up/spin-off and other types of corporate reorganizations

III. RULES ON CONSOLIDATION OF ASSESSMENT

No consolidation shall be allowed if any case has reached the FDDA stage. Cases that have reached the FDDA stage must proceed independently.
No consolidation shall be allowed if a FAN has already become final, executory, and demandable. Once finality attaches, the assessment shall no longer be disturbed.
No Consolidation of Cases Involving FAN Stage and Cases at Stages Prior to Issuance of Preliminary Assessment Notice (PAN), whether with or without a Notice of Discrepancy (NOD)to prevent undue delay in the resolution of cases at the FAN stage, in view of the remedies available to the taxpayer under Section 228 of the National Internal Revenue Code of 1997, as amended (Tax Code), including the right to appeal to the Court of Tax Appeals.
Exception: Consolidation involving any FAN-stage case may be allowed only if:

The FAN was validly issued and properly served;
The protest period is still running, or a valid protest has been timely filed;
The assessment has not yet become final and executory;
All safeguards under Section Ill(C) of this Order are complied with; and
Where a protest has already been filed, the Consolidated FAN is issued before the lapse of the applicable one hundred eighty (180)-day period under Section 228 of the Tax Code.

You may refer to the attached RMO 6-2006 for the detailed protocols and safeguards to be followed for cases nearing FAN or at the FAN stage already, as well as those at the FDDA stage.

RMO No. 06-2026 is in effect starting 04 March 2026

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

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