RMO No. 1-2024

REPUBLIC OF T H E PHILIPPINES
W DEPARTMENT O F FINANCE
BUREAU OF INTERNAL REVENUE
BUREAU O F INTERNAL REVENUE
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7 National Office Building TiW/Mi WWTC\
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Quezon City
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RbCOlWS IWI. DIVISION

November 8. 2023
REVENUE MEMORANDUM ORDER NO. P 3.0
SUBJECT Further Amending Revenue Memorandum Order No. 6-2023

Prescribing the Updated and Consolidated Policies, Guidelines and
Procedures for BIR Audit Program
TO AU Internal Revenue Officials/Officers and Others Concerned
I. OBJECTIVE
This Order is hereby issued:
1. To include as part o f Mandatory Audit those taxpayers who failed to pay taxes
declared o n tax returns filed through Electronic Filing and Payment System (eFPS)
facility o f the Bureau;
2. To amend the time frame for the submission o f reports o f investigation o f Office
Audit cases prescribed in Revenue Memorandum Order (RMO) No. 6-2023; and
3 . To reiterate policies o n handling pending audit cases o f recently classified/enlisted

Large Taxpayers.
II. AMENDMENTS
1. Item III.A.1 o f the same RMO is hereby amended to include as one o f the
Mandatory Cases to be covered by eLA the audit/investigation o f taxpayers who
consistently failed to pay/remit the corresponding taxes due reflected in the
tax returns filed through eFPS o r who later filed an amended tax returns
reflecting a decrease/no tax due. By “consistently”, w e mean taxpayer incurred
such violation for at least three (3) times in any given period. This is to enhance
voluntary compliance, at the same time, decrease future accumulation o f delinquent
taxes/accounts receivable emanating from tax returns electronically filed but taxes
due thereon remain unpaid/unremitted. (Selection Code: EFPS).
2. Item IV.C.6 of the same RMO, prescribing the time frame for the submission o f
report o f investigation o f cases covered by eLA, other than replacement eLA, is
likewise amended, as follows:
Case Classification No. of Days
Cases covered by eLAs 180 days for Regional cases/240 days for LT cases/120
other than replacement eLA days for OAS/90 days for LTVAU and VATAS from
date of the eLA
Further, the counting of the number o f days to complete audit as prescribed in the
same Item of the RMO, shall be suspended when the investigating R O requested
for the issuance of Subpoena Duces Tecum (SDT) or an Exchange o f Information
(EOI). The reckoning date for the suspension shall b e o n the date o f receipt o f
request by the concerned office, and shall only b e lifted when the reply has been
forwarded to the requesting RO:
Concerned BIR Office

Requests for issuance of SDT Legal Division/Office of the Assistant
Commissioner -Large Taxpayers Service
Requests for exchange of information Exchange of Information Unit of the

provision for taxes covered by tax International Tax Affairs Division
treaty
T o prevent the issuance o f jeopardy assessments as well as to ensure that the Bureau
is not deprived o f its right to assess and collect the right amount o f tax, the
procedures in the issuance o f S D T within two (2) working days from receipt o f
request as prescribed under Item No. III.3.5 o f R M O No. 10-2013, as amended by
RMO No. 8-2014 must b e strictly observed by the concerned office to compel
taxpayers to submit or present the required books, records and documents.
3 . Item IV.G.2.b o f RMO No. 6-2023, is likewise amended to read as follows:
“In case the taxpayer has transferred its business registration to another Revenue
District Office (RDO), or the taxpayer has been enlisted/delisted as large taxpayer,
the continuation of audit cases which has already started prior to transfer or its
enlistment/delisting as large taxpayer, shall be conducted by the old handling BIR
Office.
In the same manner, all protests against deficiency tax assessment notices [e.g.,
Preliminary Assessment Notice (PAN), Formal Letter of Demand/Final Assessment
Notice (FLD/FAN), and Final Decision on Disputed Assessment (FDDA)] issued
against transferred or newly enlisted/delisted large taxpayers, shall be handled by
the old concerned BIR Office that issued such notice until settlement/termination of
the case. Unprotested tax assessments that matured into “delinquent accounts” shall
be referred to the new concerned BIR Office where the taxpayer is registered.
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Any collection therefrom shall b e credited to the Office that conducted/concluded
the audit upon notification to the Large Taxpayers Service (LTS) o r Regional Office,
as the case may be, for proper crediting by the Revenue Accounting Division.
Thereafter, all eLAs/TVNs regardless of the taxable year shall b e issued b y the new
BIR Office having jurisdiction over the taxpayer’s registration.”
III. REPEALING C L A U S E
All provisions of revenue issuances/memoranda inconsistent herewith are

hereby repealed, amended or modified accordingly.
IV. EFFECTIVITY
This Order shall take effect immediately.
RO GUI, JR.
Co issioner of Internal Revenue
1-1
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REPUBLIC OF T H E PHILIPPINES

RbCOlWS IWI. DIVISION

REVENUE MEMORANDUM ORDER NO. P 3.0

SUBJECT Further Amending Revenue Memorandum Order No. 6-2023

TO AU Internal Revenue Officials/Officers and Others Concerned

This Order is hereby issued:

3 . To reiterate policies o n handling pending audit cases o f recently classified/enlisted

Concerned BIR Office

Requests for exchange of information Exchange of Information Unit of the

3 . Item IV.G.2.b o f RMO No. 6-2023, is likewise amended to read as follows:

All provisions of revenue issuances/memoranda inconsistent herewith are

This Order shall take effect immediately.

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