On 24 November 2025, the Bureau of Internal Revenue (“BIR”) issued Revenue Memorandum Circular (“RMC”) No. 107-2025, ordering the immediate suspension of all ongoing field audits and audit-related operations. The suspension covers the issuance of Letter of Authority (“LOA”), Mission Order (“MO”), examination, and verification of taxpayers’ books of accounts, records, and other related transactions.
The immediate suspension applies to all operating offices of the BIR that conduct field audits and related field operations, such as the following:
- Large Taxpayers Service (“LTS”);
- Revenue Regions (“RRs”);
- Revenue District Offices (“RDOs”);
- National and Regional Investigation Divisions;
- Assessment Divisions;
- VAT Audit Unit;
- VAT Audit Sections;
- Office Audit Sections; and
- All other offices, committees, and task forces authorized to conduct examinations, verification of taxpayer’ books of account, records, and other related transactions or investigations.
During this suspension period, the issuance of written orders to audit or investigate taxpayers’ internal revenue liabilities is suspended, except in the following circumstances:
- Investigation of cases prescribing within six (6) months from the date of this Order;
- 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;
- Examination or verification of internal revenue tax liabilities of taxpayers retiring from business;
- 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;
- Claims for refund where the issuance of an LOA is statutorily required; and
- Other matters/concerns where deadlines have been imposed under the orders of the Commissioner.
In addition, RMC No. 107-2025 requires all concerned offices, committees, and task forces to submit an inventory of all pending or unserved LOAs, revalidated, expired LOAs, and supplementary or related LOAs, MOS, including their status, within fifteen (15) working days from the effectivity date. During the suspension period, no revalidation, extension, replacement, or supplementary LOA and MO shall be issued unless it falls under the exceptions mentioned above.
Lastly, RMC No. 107-2025 provides that the failure to comply with this Order shall constitute an administrative offense. All erring personnel shall be subject to appropriate disciplinary action, without prejudice to any applicable civil or criminal liability.
This guide provides a general overview of the above transactions at the time of writing only and is not intended to be a comprehensive legal advice. This should also not be taken as an opinion on the topic. For more details and information, you may coordinate with any GVES Law Partner regarding the matter.
Atty. Feleo C. Quijano is an Associate at GVES Law.