BIR has issued Revenue Memorandum Circular (RMC) No. 14‑2026 dated March 04, 2026, clarifying provisions of RMC No. 08‑2026 (lifting of suspension of tax audits), RMO No. 01‑2026, and RMO No. 06‑2026 on revised audit policies, procedures, and safeguards.

  1. Authorized Audit and Verification Instruments
  1. Replacement eLAs due to reassignment of Revenue Officers are administrative adjustments, not new audit authorities.
  2. LOAs/eLAs issued prior to RMO No. 1‑2026 remain valid.
  3. Mandatory labeling applies only to new audit instruments; prior LOAs/eLAs remain enforceable.
  4. Tax Verification Notices (TVNs) are limited to the specific transaction stated; expansion requires a separate eLA.
  5. Replacement eLAs cannot expand coverage to new taxable periods.
  6. Filing a letter questioning a Replacement eLA does not suspend or delay audits.

2. Single‑Instance Audit Framework

  1. Multiple eLAs covering the same taxpayer and taxable period will be consolidated into a single eLA.
  2. Taxpayers may file a Request for Non‑Consolidation of VAT cases until March 13, 2026; separate proceedings allowed only until May 15, 2026.
  3. Paid and settled liabilities prior to replacement eLAs are recognized as closed and cannot be reassessed.

3. System‑Assisted Audit Initiation and eLA Issuance

  1. Audit selection criteria may be modified by the CIR to align with compliance strategies.
  2. Verified complaints or information from informers/government agencies may trigger audits, subject to legal evaluation under RR No. 16‑2010.

4. Consolidation of Pending Audits

a. Important dates to remember for purposes of consolidation

  • March 13, 2026 – Deadline for non‑consolidation requests.
  • March 20, 2026 – Automatic consolidation of multiple LOAs/eLAs.
  • May 15, 2026 – Deadline for VAT audit offices to prepare cases for transfer.
  • May 18, 2026 – Automatic consolidation of all pending LOAs/eLAs.
  1. Replacement eLAs must be properly served to taxpayers.
  2. Existing waivers of prescription remain valid under replacement eLAs.
  3. Prior notices, subpoenas, and document requests remain enforceable.

5. Transfer and Dissolution of VAT Audit Office

  1. VAT Audit Section (VATAS) and Large Taxpayers VAT Unit (LTVAU) may continue processing audits only until May 15, 2026.
  2. After dissolution, all case dockets, evidence, and working papers must be formally turned over to regular BIR offices by May 29, 2026.