The BIR has issued RMC No. 109‑2025 on December 12, 2025, clarifying the scope of the audit suspension under RMC No. 107‑2025.

KEY POINTS:

Suspension Coverage

  • Effective November 24, 2025, all field audits and related operations are suspended until lifted by the Commissioner of Internal Revenue (CIR).
  • Activities suspended include issuance of Letters of Authority (LOAs), Mission Orders (MOs), Tax Verification Notices (TVNs), Subpoena Duces Tecum, and audit‑related fieldwork.
  • Applies nationwide to all BIR offices conducting audits.

Exceptions (Audits/Actions Still Allowed)

  • Cases prescribing within 6 months from November 24, 2025.
  • ONETT cases (estate tax, donor’s tax, CGT, DST, withholding tax on property sales).
  • Taxpayers retiring or closing business (mandatory audits for tax clearance).
  • Criminal tax cases (tax evasion, fraud investigations).
  • Refund claims and Tax Credit Certificate (TCC) applications where LOA is required.
  • Matters with statutory deadlines or CIR‑ordered deadlines.

Other Clarifications

  • Taxpayers must continue filing and paying taxes as usual; only field audits are suspended.
  • Collection activities (e.g., warrants, distraint, levy, garnishment) for delinquent accounts remain enforceable.
  • Voluntary settlement of deficiency taxes is allowed during the suspension.
  • BIR offices must submit inventories of pending LOAs/MOs within 15 working days from effectivity.
  • Suspension will remain until formally lifted by the CIR.

Implication for Taxpayers

  • No new or ongoing field audits unless covered by exceptions.
  • Compliance obligations (filing and payment of taxes) continue as normal.
  • Taxpayers with pending refund claims, ONETT transactions, or nearing prescription cases may still be subject to audit.