RMO No. 36-2025 — Further Amending Revenue Memorandum Order No. 6-2023, Prescribing the Updated and Consolidated Policies, Guidelines and Procedures for BIR Audit Program

BUREAU OF INTERNAL REVENUE REPUBLICOF THE PHILIPPINES DEPARTMENT OF FINANCE

Bringing In Revenues for Nation-Building National Office Building Quezon City July 17, 2025 PILIPINAS BAGONG

REVENUE MEMORANDUM ORDER NO. 036-2025

SUBJECT: Further AmendingRevenueMemorandum Order No. 6-2023

Procedures for BIR Audit Program Prescribing the Updated and Consolidated Policies, Guidelines and

TO All Internal Revenue Officials/Officers and Others Concerned

I OBJECTIVES

To prescribe cases subject to mandatory audit that shall be covered by an electronic Letter of Authority (eLA)

2 To prescribe policies for mandatory cases covered by an eLA; and

3. To amend certain provisions of Revenue Memorandum Order (RMO) No.6-2023, as

Clearance Certificate of Liabilities (TCL) for business closure, cessation of business up/spin-off and other types of reorganizations. amended by RMO Nos.8-2023,1-2024 and 17-2024, concerning the issuance of Tax registration due to death, and for corporations undergoing merger/consolidation/split

II.AMENDMENTS

I Item No.III of RMO No.6-2023, as amended, is hereby further amended to read as follows:

IIL.INVESTIGATION/VERIFICATION OF TAXPAYERS

XXx XXX XXX

A.Mandatory Cases --xxx...

To be covered by eLAs

3 BUREAU OFINTERNALRFVENUE ECORDS MANAGEMENT DIVISION AUG 18 2025 F 1.3 xxx. I.I xxx... 1.7 Taxpayers with VAT returns reflecting erroneous 1.2 xxx. 1.4 xxx. 1.5 xxx. 1.6 xxx. input tax carry-over Selection Code ITCO

B ADMIN UNIT. TIME: tg:yu 1.8 Taxpayers with a Mission Order (M0) where purposes and that the veracity of its accounting preliminary findings indicate that the taxpayer has an Tecords is not reliable understatement of sales by 30% or more for tax MO

BIR National Office Bldg., Senator Miriam Defensor-Santiago Avenue, Diliman, Quezon City Trunkline: 8981-7000 ;8929-7676 Website: www.bir.gov.ph

1.9 Occurrences of non-compliance with tax obligations arising from Spontaneous Exchange of Information Selection Code SEOL

1.10 Policy cases/industry issues under the directive of the Commissioner MCIR"

2.To facilitate the timely issuance of TCL to taxpayers who are retiring from business. or undergoing merger/consolidation/split-up/spin-off and other types of corporate reorganizations,and are subject to mandatory audit pursuant to either electronic Letter

IV.D.2 of RMO No. 6-2023, as amended, is hereby further amended to read as follows: of Authority (eLA)/Tax Verification Notice (TVN), the policy stated in Item No.

ADMIN TE To C AUG 18 25 FAINTERNENT UREAU LREVENU where the taxpayer is registered, with a copy of the TL together with the approved to ensure that TCl shall only be issued upon full settlement of any deficiency tax cases or cases with no findings/discrepancy shall be prepared by the Assessment Division of the Regional Office/concerned Large Taxpayers Audit Division of the Large Taxpayers Service (LTS) upon approval of audit reports by the Regional Director/Assistant Commissioner-L TS. The said TL shall then be forwarded to the taxpayer by the office "2. A Termination Letter (TL), following the herein template (Annex "A"), on all paid responsible for its preparation. For regional cases where eLA/TVN was issued pursuant to Item III.A.1.2 and III.A.2.1 hereof, whichever is applicable,the Assessment Division shall furnish the concerned RDO memorandum report recommending the closure/cessation of business registration. This is assessments.

National Office for appropriate closure of the case status in the IRIS-CMS-A. cause the immediate transfer of the case custody in the IRIS-CMS-A to the Administrative and Human Resource Management Division of the Regional Office/Records Division of the The Assessment Division/Office of the Head Revenue Executive Assistant of the LTS shall

III. SUPPLEMENTAL POLICIES

1 The audit of the mandatory ITCO cases shall be conducted by the VAT Audit Section

has not yet been institutionalized, the audit shall be carried out by the Revenue District Office (RDO) that has jurisdiction over the taxpayer's registration. (VATAS) of the Assessment Division.However, in Regional Offices where VATAS

T Based on the result of surveillance activities conducted pursuant to an MO, the eLA to be issued shall cover the taxable year immediately preceding the period of the enforcement operations.

IV. Repealing Clause

accordingly. All other issuances inconsistent herewith are hereby modified or repealed

V. Effectivity

This Order shall take effect immediately.

Commissioner of Internal Revenue ROMEO D.LUMAGUI, JR.

RMO RE:Further Amending RMO No. 6-2023, Prescribing the Updated and Consolidated Policies, Guidelines and Procedures for BIR audit Program July 17,2025 aoe 20f