BIR has issued RMO 6-2026, which provides amendments, supplemental procedures, and clarificatory guidelines for the implementation of RMO No. 1-2026.

Key Highlights:

  1. Amendment of Implementation Dates:
EVENTFROMTO
Deadline for filing written Requests for Non-Consolidation of VAT Audit CasesFeb 16, 2026Mar 13, 2026
Automatic consolidation of all pending eLAs except where a written Request for Non-Consolidation is duly filedMar 4, 2026Mar 20, 2026
Last day of audit operations for VAT Audit Sections  (VATAS) and Large Taxpayers VAT Audit Unit (LTVAU)Apr 30, 2026May 15, 2026
Automatic consolidation of all pending eLAs which were previously allowed to proceed separately pursuant to a Request for Non-ConsolidationMay 4, 2026May 18, 2026
Last day of VATAS and LTVAU for purposes of winding up its operationsMay 15, 2026May 29, 2026
  1. Item No. 7 of the Annex A – Mandatory Case (To be covered by LOA) shall now read as follows: ”Taxpayers requesting Tax Clearance whose gross sales of the immediately preceding year exceed P3,000,000 or whose gross assets upon retirement exceed P8,000,000…”
  1. Absolute prohibitions on the consolidation of assessment:
  1. No consolidation at Final Decision on Disputed Assessment (FDDA) stage
  2. No consolidation of final and executory Final Assessment Notice (FAN)
  3. No consolidation of cases involving FAN stage and cases at stages prior to issuance of Preliminary Assessment Notice (PAN)
  4. Exception: Consolidation at the FAN stage may be allowed only if the conditions prescribed under this RMO are satisfied.
  1. Mandatory Safeguards: For permitted consolidations at the Notice of Discrepancy (NOD), Preliminary Assessment Notice (PAN), or FAN stages, strict safeguards must be observed. These include securing a Written Conformity to Consolidation from the taxpayer and a Waiver of Prescription.
  1. VAT Refund Jurisdictions: The VATAS and LTVAU will only accept new VAT refund applications until March 31, 2026. Beginning April 1, 2026, all new refund applications must be filed with and processed by the appropriate Revenue District Office or the Large Taxpayers Service.