BIR RMC 106-2025 Suspension of all field audits

The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular (RMC) 106-2025 on November 24, 2025 ordering the suspension of all ongoing field audits and related field operations until the Commissioner of Internal Revenue lifts the order. The BIR intends to review the audit operations on tax assessments in the Philippines.

Suspended field operations include:

·      Issuing Letter of Authority (LOA);

·      Mission Order (MO);

·      Examination and Verification of Taxpayer’s books of accounts; and,

·      Other related transactions.

Who is covered by the BIR Audit Suspension?

BIR RMC 106-2025 notes that the suspension applies to all operating offices of the BIR conducting field audits and related field operations, including but not limited to:

1.     Large Taxpayers Service (LTS);

2.    Revenue Regions (RRs);

3.    Revenue District Offices (RDOs);

4.    National and Regional Investigation Divisions;

5.    Assessments Divisions;

6.    VAT Audit Units (LTS);

7.     VAT Audit Sections.

8.    Office Audit Sections; and,

9.    All other officers, committees, and task forces authorized to conduct examinations, verification of taxpayers’ books of account, records, and other related transactions or investigations.

What are the exceptions to the BIR Audit Suspension?

The RMC also clarifies issuance of written orders to audit or investigate taxpayers’ internal revenue liabilities is suspended, except in the following circumstances:

1.     Investigation of cases prescribing within six (6) months from the date of the Order;

2.    Processing and verification of estate tax returns, donor’s tax returns, capital gains tax returns, and withholding tax returns on the sale of real properties or shares of stocks, together with the documentary stamp tax returns related thereto;

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 if an LOA is statutorily required; and,

6.    Other matters/concerns where deadlines have been imposed or under the borders of the Commissioner.