RMO No. 4-2025 — Policies and Guidelines in the Reporting of Cannot be Located (CBL) Taxpayers and Procedures in Handling the Cases Pertaining Thereto Digest | Full Text | Annexes

Bringing In Revenues for Nation-Building BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE Quezon City PILIPINAS BAGOnG

REVENUE MEMORANDUM ORDER NO 004-2025

SUBJECT Policies and Guidelines in the Reporting of Cannot be Located (CBL) Taxpayers and Procedures in Handling the Cases Pertaining Thereto

TO All Internal Revenue Officials, Employees and All Others Concerned

OBJECTIVES

This Order is issucd to:

1. Provide a common understanding of a CBL Taxpayer;

Ys 1L0744 NYT C taxpayers and those responsible for its publication through the official BIR website; Identify concerned offices that shall be responsible for the approval of the List of CBL (RO) that a particular taxpayer is a CBL Taxpayer; Identify the acceptable documents that will support the report of the Revenue Officer

w . Provide the policies and procedures when published CBL taxpayers are found/located or have resurfaced;

CBL taxpayers who have received a Letter of Authority (LOA) prior to being tagged as CBL; Provide guidelines and procedures in the issuance of tax deficiency assessments to

6. Provide policies and procedures on reporting of dockets of CBL taxpayers with reported delinquent accounts; and

7. Prescribe the procedures for the tagging and un-tagging of the CBL status of these taxpayers in the Internal Revenue Integrated System -- Tax Registration System (IRIS-TRS).

H. POLICIES AND PROCEDURES

A. CBL TAXPAYERS

means have been exhausted as provided in Item II.B(1) hereof: The following taxpayers shall be considered as CBL Taxpayers after all possible

BlR National Office Bldg., Senator Miriam Defensor-Santiago Avenue, Diliman, Quezon City Trunkline: 838$9760f 18929-7676 Website: www.bir.gov.ph

1. Taxpayers registered with this Bureau who are not found in their registered addresses, who may or may not be filing the required tax returns; or

2. Taxpayers who are registered, but upon post-registration ocular inspection, their whereabouts could not be established, or whose indicated addresses are non-existent; or

3. Taxpayers whose registered address was found to be a "virtual office" and where no authorized person is available to receive any correspondences addressed to them.

by different taxpayers. For the purposes of this Order, a "virtual office" shall mean a shared office utilized

B. REPORTING OF TAXPAYER AS CBL

SZOZ 7I NVf E 87 f In order to establish if a particular taxpayer is a CBL taxpayer, the concerned RO include, but are not limited to the following: handling the case shall, after conducting the post-registration ocular inspection of its registered business address and/or failing to serve letters / correspondences and other notices, exhaust all possible means available to locate the taxpayer. These efforts to verify or confirm that the taxpayer is indeed a CBL taxpayer, shall Collaboration with relevant government agencies / instrumentalities, public connected with the taxpayer. service-oriented entities, suppliers, purchasers and other businesses possibly

Verification of social media platforms such as Facebook, Instagram, streaming whereabouts of the taxpayer. media and the like must be resorted to, in getting information on the possible

Sending correspondences or notices to the taxpayer's registered electronic mail address or to its authorized tax agent on record, if any.

d. Analysis of Summary List of Purchases/Sales pertaining to the concerned taxpayer and random checks with any of their suppliers or customers to determine the whereabouts of the taxpayer.

e. Coordination with the Revenue District Office (RDO) having jurisdiction over

as a "branch" to obtain latest information on the branch location or possible service of notices through the head office of the said branch. the head office of the taxpayer must be made in case the taxpayer is registered

Sending correspondences or notices to the accountable officers in case the amended. taxpayer is a corporation pursuant to Section 30 of the Corporation Code, as

g Sending correspondences or notices to the Certified Public Accountant indicated in the financial statement (current or previous years) filed with the Securities and Exchange Commission (SEC).

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sent correspondences, advise the taxpayer to update their registration details. particularly the registered address. If the handling RO found the taxpayer or there is an acknowledgement of the

2. In case the aforementioned undertakings did not provide favorable results, the following procedures shall be implemented:

a Obtain a certification from at least two (2) of any of the following government offices/agencies (one per office/agency) to support or confirm the non-existence / non-compliance / inactive status of the taxpayer:

Name of Agency Rcquircment Municipal / City Permit / Licensing Office Government Business business registration and that the latest record of its business/residential address is the same as the registered addressed provided with the BIR A Certification that the particular person did not renew its

Municipal / City /Provincial Assessor's Office Certificate that the concerned person has no Property Holdings or Certificate of Property Holdings SNS (C S70744 Nf C T W T E Commission on Election (COMELEC) Department of Trade and Industry (DTI) Social Security System Registry of Deeds Securities and Exchange Commission (SEC) (SSS) contribution to SsS, as self-employed or as employer Certificate that it has no record of the particular person as Latest General Information Sheet and Audited Financiai List of Real Properties, including the known address of Certificate of Non-Renewal of Business Registration as well as the Latest Known Address per their record Certificate that the person has no record of any Voter Certificate that the concerned corporation did not file Statement the concerned person

Corporation (PHIC) Authority (PSA) Philippine Health Insurance Philippine Statistics Philhealth Contributions Death Certificate (for individual) Certificate that the concerned party has no record of

Insurance Commission (IC) Certificate of Non-Compliance in the submission of required reports, including the latest known address of the concerned person Home Deveiopment Mutual Fund (PAG-IBIG) Certificate that the concerned party has no record of PAGIBIG Contributions

Employment (DOLE) Bangko Sentral ng Pilipinas (BSP) Department of Labor and required reports, including the latest known address of the concerned person required reports, including the latest known address of the concerned person Certificate of Non-Compliance in the submission of Certificate of Non-Compliance in the submission of

(LTO) Land Transportation Office owner of vehicle or as driver Licensee Certificate that the concerned person has no records as

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b. Obtain at Ieast one (l) document certifying the non-existence of a CBI taxpayer from other well-established and credible offices, organizations. institutions, establishments and business entities connected with the entrepreneurial or personal activities of the taxpayer such as, but not limited to:

Homeowner's Association, Cooperatives, Recreational Clubs, etc. Water Utilities Companies Philippine Long Distance Telephone Company (PLDT)" or other Manila Electric Company (MERALCO) or other Electric Companies telecommunications companies / Internet Service Providers

For social media platforms such as Facebook, Instagram, streaming media and location or map posted in an online advertisement found to be non-existent or fictitious upon ocular inspection. the like, a screenshot of taxpayer's business address or photo of the business

N R SLOL7T NVf T k A Wa ett The above information shall be included in the mcmorandum report referred to in Item II.B.2(e) hereof. business (e.g., Affidavit, written Complaint, etc.). Other sources of information can be taken from the Barangay or from a but lost contact due to the absence of the taxpayer in its original place of third-party source who was formerly transacting business with the taxpayer

( 3 If the taxpaycr is subject of audit, the RO assigned to the case shall secure a list the RO conducting audit to submit "List of Assets" (Annex A). jurisdiction over the properties located within the concerned RDO in Municipal/City. Assessor's Office or from the Registry of Deeds which has accordance with Revenue Memorandum Order (RMO) No. 26-2010 requiring of assets/properties of the CBL taxpayer, if any, from thc Provincial/

2 Within sixty (60) days from the date of ocular inspection, or from the last

of thc taxpayer as CBL, to the Head of Officc for approval, through the assets/properties, if any. together with their Joint Sworn Affidavit (Annex B.1), establishing the status immediate supervisor, together with the supporting documents and the list of attempt to serve correspondences/notices which resulted to failure, the concerned ROs and GS shall submit a Memorandum Report (Annex B)

f The Head of Office shall approve/disapprove the Memorandum Report submitted by the concerned RO within two (2) days from receipt thereof.

Non-compliance/erroneous/falsification of the documentary proofs to establish the CBL status of the taxpayer shall be a ground for the imposition of administrative sanction against the erring ROs.

3. Upon approval of the RO's Memorandum Report (Annex B), the handling RO/GS/concerncd Revenue Official shall undertake the following actions should

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audit/investigation: the taxpayer's CBL status has transpired during the service of LOA or conduct of

a.If the LOA was not served, update the case status in either electronic Letter of Authority Monitoring System (eLAMS) or Internal Revenue Integrated System following thc procedures below: - Case Management System -- Audit (IRIS-CMS-A), whichever is applicable,

a.1 LOA was issued in eLAMS - encode the term "CBL" in the "Remarks" column; and

a.2 LOA was issued in IRIS-CMS-A - click the "Case Status" tab then click the "Suspend Case" tab and select "CBL" as the reason for suspending the case.

PANA SZOZ 4INVf 3 Waatt*ia logged in the Service Desk followed by an approved Data Fix Request To temporarily remove the case from the inventory of the handling RO/Group Supervisor (GS), a request for data fix in IRIS-CMS-A shall be Form for submission to Administrative Systems Division (ASD): The " F e e E IATiNUE latter shall "end date" the assignment of the case to the RO/GS. attached to the Data Fix Request Form. The duly approved Memorandum Report by the Head of Office must be

b. The handling RO shall prepare a list of these unserved LOA for safekeeping and have it received by the CMS Officer/designated custodian for future reference.

c. In case the LOA was served, the handling RO/GS shall prepare the necessary (NOD/DOD) in order to establish a report on the taxpayer's deficiency of any internal revenue taxes. If service of notices requesting for the presentation of accounting records/documents has not been served due to the taxpayer being classified as CBL, the report of investigation and NOD/DOD shall be based on available documents or best evidence obtainable (BEO) rule. Relative thereto, the issuance of a Subpoena Duces Tecum (SDT) shall not be required to justify the tax assessment based on BEO rule. The Head of Investigating Office shall subsequently endorse the case to the Reviewing Office for issuance of a Preliminary Assessment Notice (PAN). report of investigation and Notice of Discrepancy/Details of Discrepancies

4. The Reviewing Office shall review the report and proposed tax assessment and be covered by a Transmittal Letter. All unserved notices shall form part of the case docket and shall be served simultaneously when the taxpayer resurfaced. cause the issuance of PAN. Thereafter, the case status in eLAMS or IRIS, whichever is applicable, following the procedures under B.3.a.1/a.2, must be (RMD) for National Office cases or to the Administrative and Human Resource Management Division (AHRMD) for regional cases, for safekeeping. This shall updated, before forwarding the case dockets to the Records Management Division

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5. The approved Memorandum Reports (Annex B) submitted by the ROs shall be shall be approved by the herein indicated Revenue Officials: consolidated to come up with the Report on CBL Taxpayers (Annex C), which

A I SZO2 VINYf A HvE 2t R reported and published as CBL Taxpayers with unserved LOA/ Notice of Discrepancy/ Preliminary Assessment Notice/ Final Assessment Notice and audit/investigation, and person available other Taxpayers not found in the registered address registration/ ocular inspection or those Office address and have no authorized (WDL) who. have not been previously with verification. Taxpayers found to be using a Virtual correspondences and notices. Letter/Warrants of Distraint and/or Levy Taxpave Scenarios for Identifying CBL unserved upon withunserved Collection notices Taxpayers conduct to tax related receive I compliance Of post- BIR to Division (LTD)-Cebu, Large Taxpayer Division -Davao, Assessment Division (AD), Taxpayers VAT Audit Unit Assistant Revenue District Officer (ARDO)/Assistant {ARMD), Large Taxpayer Division Chiefs (ADC) of Collection Division (CD) Divisions, Chief of Large Division (NID), Regional Preparation of the (RID), Large Taxpayer Collection Enforcement National Investigation Investigation Division Regular/Excise Large "Rcport on CBL Monitoring Division Taxpayer (LT) Audit Accounts Receivable Division (LTCED), Taxpayer" Annex C (LTVAU) Chief (DC) / Head Officer / Division Revenue District] Approval of of Office, as the the "Report Taxpayers" case may be on CBL

1 The approved Report on CBL Taxpayers (Annex C) shall be duly notarized by a

notary public and shall be submitted to the office of the respective Assistant Regional Director (ARD)/Head Revenue Executive Assistant (HREA) on or before the 1oth day following the month it was reported as CBL.

LTVAU, the same shall be submitted to the respective HREA. Copies of the approved Report on CBL Taxpayers (Annex C) of ARMD and NID shall be submitted to the concerned regional offices which have jurisdiction over the CBL taxpayers. However, in the case of CBL taxpayers identified/reported by LTCED, LTD-Cebu, LTD-Davao and Regular/Excise LT Audit Division,

7. The ARD for Regional Offices or the concerned HREA for LTS shall appoint taxpayer's registration information found in the Burcau's database. personnel to validate and countercheck the veracity of the information stated in the Report on CBL Taxpayers (Annex C) as against the Bureau's registration system. The taxpayer's registration information in the report should match with the

8. The ARD/concerned HREA-LTS shall prepare the Consolidated List of CBL submitted by RDOs/DCs. The same shall be forwarded to the concerned Regional Director/ACIR --LTS for approval. Taxpayers (Annex D) culled from the Reports on CBL Taxpayers (Annex C)

9. The hard and soft copies of the Annex D, together with the original copies of the duly notarized report (Annex C), shall be submitted by ARD / concerned LTS

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Regulatory Division (ELTRD) for excise large taxpayers. HREA within twenty (20) working days from the close of each month 'to the Assessment Service (AS), Attention: Audit Information Tax Exemptions and Incentives Division (AITEID), for uploading in the BIR Website (www.bir.gov.ph). Copies of Annexes C and D shall be furnished to the Chief, Client Support Section of the RDO (CSS-RDO), Chief, Large Taxpayer Assistance Division (LTAD) for regular large taxpayers and Chief, Excise Large Taxpayer

C. PUBLICATION OF LIST OF CBL TAXPAYERS AND TAGGING OF "CBL"

STATUS IN THE REGISTRATION DATABASE 1. AITEID shall upload to the BIR Website the submittcd consolidated list from the thru a memorandum, all offices concerned of the date of publication of the subject CBL taxpayers. Regional Offices/Office of the concerned HREA of the LTS within five (5) days from receipt thereof. Upon uploading to the BIR Website, AITEID will informj

BE W E S704L NYT U T t'tm 2. After publication/posting to the BIR Website, the AITEID shall request, through a ASD for the mass tagging of CBL taxpayers in the IRIS-Tax Registration System memorandum, copy furnished the ACIR of the Client Support Service (CSS), the be consolidated and forwarded by AITEID, to the ASD. (IRIS-TRS). The soft copy of the list of published/uploaded CBL taxpayers, shall

V v49ne w 3. The ASD shall perform the mass tagging of the CBL taxpayers in IRIS-TRS based inform AITEID through a memorandum, copy furnishcd ACIR-CSS and ACIR AS. the date of the rcceipt of request. After completion of the request, the ASD shall on the consolidated list forwarded by AITEID, within five (5) working days from

4. The CSS through the Internal Communications Division (ICD), shall issue an with the instruction on what the taxpayer should do if they see their names in the 1ist. "ADVISORY" on the newly published Iist of taxpayers tagged as "CBL", together

D. SAFEKEEPING OF UNSERVED CORRESPONDENCES/RELEVANT CASE DOCKET (AUDIT/COLLECTION CASE)

1.A copy of the notarized "Annex C" report shall be kept in the custody of the Office of the ARD and concerned HREA of LTS for future reference.

2. All notices and correspondences relative to audit, cxcept unserved LOA

by the investigating office's designated custodian or CMS-A Officer for easy [e.g., First/Final Notice for presentation of records/books, SDT, NOD/DOD, PAN, Formal Letter of Demand/Final Assessment Notice (FLD/FAN), Final Decision on Disputed Assessments (FDDA), and other relevant letters/correspondences] must be attached to the case docket and the same shall be forwarded to the RMD/AHRMD, for safekeeping and future reference. Unserved LOA must be kept retrieval once the taxpayer resurfaced.

3. Likewise, unserved collection notices and other relevant correspondences must be attached first to the case docket by the office enforcing the collection remedies

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safekeeping. before it can be forwarded to the RMD/AHRMD, as the case may be, for

4. A CBL docket may contain any of the unserved notices, and any of the documents the taxpayer's whereabouts. mentioned under Item II.B 2 (a and b) hereof that will prove the non-existence of

5. Identified custodians shall maintain an excel file record of all taxpayer tagged as CBL. notices/correspondences and provide a separate and sccured area/rack for all CBL dockets under their respective possession, for easy retrieval upon resurfacing of the

E. POLICIES AND PROCEDURES ON DOCKETS OF CBL TAXPAYERS

reported as Accounts Receivable/ Dclinquent Accounts (AR/DA), thc following shall WITH DELINQUENT ACCOUNTS - For docket of CBL taxpayers that are aIready

be observed:

we ' RR * SLO2YINV I N "M W In case of execution of summary remedies, the CD/ARMD/LTCED/LTD- whereabouts and secure documents (certifications and other substantiation) to support its non-existence. If it yielded a negative result, regardless of whether the Section V No. 8a per Annex E of RMO No. 11-2014, as amended, provided that Cebu/LTD-Davao shall conduct validation on the non-existence of the taxpayers' same has been published or not, it shall be recommended as a "Suspense Account" to be classified as "11-F-A", as prescribed under Section IV No. 7f and the CBL taxpayer has no distrainable or leviable property.

Approved CBL dockets under CD/ARMD/LTCED/LTD-Cebu/LTD-Davao shall List Report of the aforementioned offices for continuous monitoring and validation. remain in the custody of thesc offices through their respective identified custodian. Likewise, the cases under these CBL dockets shall remain in the AR/DA Inventory

3. All CBL dockets published and tagged as "11-F-A" shall be recommended for support the non-existence of the taxpayers are completed and have yielded negative results for three (3) consecutive rounds. The interval for validation must be for a write-off, provided that the validation on the existence of the taxpayer's whereabouts and securing of documents (certification and other substantiation) to

minimum of twelve (12) months.

To illustrate:

existence and whereabouts are as follows: The docket was reported as AR/DA on April 1, 2019, and validation as to its

Round 2nd 3 td 4th 5 th Ist November 10, 2020 September 8, 2023 Date of Validation October 5, 2019 August 5, 2022 May 5, 2021 Result of Validation Negative Negative Negative Negative Negative Count 1 0 0 1 1

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A October 10, 2023 Negative

In the scenario provided, the first round was not considered because it was the outcome of the initial check, which would serve as the basis for the subsequent fifth validations are counted as they met the criteria of a minimum 12-month interval between validations. Given that there were three rounds of checking that validations. The second round was considered as it had passed the minimum 12 months interval since the previous validation. However, the third round was resulted in negative outcomes, the CBL account is now eligible for write-off. conducted within a period shorter than 12 months thus, not counted. The fourth and

Round 2nd 3d 4th 5 th Ist 6th Conducted more than 13 months after the initial validation Conducted less than 6 months after the last validation There had been 15 months after the last validation There had been 13 months after the last validation Only more than l month from the last validatior Initial check/validation Remarks

issued pursuant to RMO No. 33-2018, as amended, upon approval of the recommendation for write-off and completion of the above-required validation. Moreover, a corresponding Authority to Cancel Assessment (ATCA) shall be

M SZOZNV w 'LiN N a Wd Individual/Non- Individual, whichever is applicable, to settle the tax liability. Subsequently, the OD shall accomplish the Annex F and indorse the delinquent CBL taxpayer to the concerned RDO for un-tagging and updating the registration the reporting BIR Office using Annex "F". the Day (OD) shall verify from the Masterlist of CBL Taxpayers uploaded in the BIR Website which office reported the taxpayer as CBL. If the taxpayer was reported as CBL by the assisting CD, the OD shall require the resurfaced taxpayer or the authorized officer to execute the Affidavit of Undertaking (Annex "E") for details. On the other hand, if the resurfaced taxpayer was reported as CBL by CL from another Revenue Region/Investigating Office, the same shall be indorsed tc shall be forwarded to the RMD/AHRMD for safekeeping for another seven (7) years subject to existing policies provided by RMO No. 17-2023. In the event that the delinquent CBL taxpayer resurfaced at the CD, the Officer of The physical dockets of CBL accounts approved for write-off with issued ATCA

concerned who has the current jurisdiction on the resurfaced CBL taxpayer shall continue the collection summary remedies. (Annex "H"), the previously issued ATCA shall be revoked by the concerned office which issued the ATCA, if applicable. Nonctheless, the collection office Thereafter, and upon receipt of a copy of the Report of Resurfaced CBL Taxpayers

No AR/DA dockets shall be reported as CBL without the review and approval of the Authorized Officer nor shall an ATCA bc issued without duly approved recommendation for write-off. Accordingly, the collection office concerned shall ensure that dockets recommended and approved for write-off are microfilmed and a copy of the samc be retained for future reference.

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F. IMPACT OF TAGGING A PARTICULAR TAXPAYER AS "CBL"

1. The period of limitation upon assessment and collection under Sections 203 and 222 of the National Internal Revenue Code (NIRC) of 1997, as amended, shall be suspended from the date the Memorandum Report (Annex B) of the RO declaring one of the situations wherein the Commissioner is prohibited from making the the statute of limitations shall resume upon the service of any previously unserved correspondence/notice. the taxpayer as CBL has been approved by the concerned Head of Office, being assessment or beginning distraint or levy or a procecding in court. The running of

E FS 20IN C E W 2. Notwithstanding the suspension of the period of limitation for assessment and Doing Business and Efficient Delivery of Government Services,"' shall not apply. With CBL status. Any BIR office processing various application of taxpayers, such as but not limited if the applicant is among those tagged as CBL. In this case, the number of days to process / deliver the aforesaid frontline serviccs, as mandated under existing The aforesaid frontline services shall include a note in its steps and processes that the total processing time in the BIR Citizen's Charter shall not apply to applicants Taxpayer Registration Information Record, Application for Authority to Release Imported Goods, Application for Tax Clearance and electronic Certificate Authorizing Registration (eCAR), shall include in thcir procedure the verification revenue issuances in accordance with RA No. 11032 "An Act Promoting Ease of offices. On the other hand, the list of CBL Non-Individual Taxpayers shall be provided to SEC/Cooperative Development Authority for purposes also of alerting to Registration of Books of Accounts, Application for Authority to Print (ATP) Invoices, Application for Permit to use CRM/POS/SPM and other invoice Computerized Accounting System and/or its components, including Electronic Storage System (ESS), Middleware and Other Similar Systems, Updating of the BIR in casc the listed names have transactions with them. generation machine, Application for Permit to Use Loose Leaf, Registration of The List of CBL Individual Taxpayers per published Consolidated List of CBL National Bureau of Investigation (NBD, Philippine National Police (PNP) and Bureau of Immigration (BI), together with a letter requcsting these agencies to alert the BIR in case the listed taxpayer is securing clearance from thcir respective available documents or BEO rule, in cases where the notices requesting the justify the assessment based on BEO. The taxpayer's right to a Discussion of Discrepancy as indicated in the NOD shall be forfeited, and the PAN shall be issued, accordingly. Taxpayers (Annex D) shall be provided by the ARD / ACIR-CS/LTS to the DTI. collection upon approval of the Memorandum Report, the concerned Head of Investigating Office is required to issue NOD/DOD to document the taxpayer's deficiency in any internal revenue tax. The NOD/DOD shall be prepared based on presentation of accounting records and documents have not been served due to the taxpayer being classified as CBL. The issuance of SDT shall not be necessary to

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5. ROs handling audit or refund cases must verify from the published list of CBL taxpayers if there are expenses/input taxes being claimed by the auditee-taxpayer arising from transactions with CBL taxpayers.

for Income Tax purposes, and if the transaction is with Value Added Tax componcnt, the same cannot be claimed as input tax, unless the buyer can prove the existence of the supplier tagged as CBL by the BIR and the authenticity. Purchases made from a published CBL taxpayer shall not be allowed as deductions of purchases made. The RO handling the audit case of the buyer shall report it to the RDO which declared the particular taxpayer as CBL.

G.REAPPEARANCE OF TAXPAYERS TAGGED AS "CBL"

1. In case a CBL taxpayer has resurfaced/reappeared in any of the BIR district offices

of the assisting RDO shall observe the following procedures: or has becn endorsed by the concerned Regional Collection Division, the RO-OD

a Verify from the Masterlist of CBL Taxpayers uploaded in the BIR Website

which the BIR office reported the taxpayer as CBL.

b After verification, if the taxpayer was reported as CBL by another office (e.g..

AN Ae H rS Ysx SZOZ vI NVf E X E W 8T accomplish the indorsement form (Annex F) and advise the resurfaced taxpayer to: (i.) proceed to the BIR office which reported the said taxpayer as CBL (which shall continue the procedures hereof); and (ii.) submit to such office the If reported by the assisting RDO, the OD shall retrieve the docket of the CBI taxpayer from the concerned RMD/AHRMD or from the office which reported the taxpayer as CBL, to determine the pending issues that should be resolved. other RDO, CD, ARMD, NID, Offices under LTS), the said OD shall official indorsement from the assisting RDO.

Upon retrieval of the docket, the OD shall refer the resurfaced taxpayer to the concerned section/office based on the reason why the said taxpayer was tagged as CBL:

Reason for Tagging Refer to: Not found in the registered address upon post-registration ocular inspection The Chief, CSS-RDO

Sent notices regarding stop-filer cases and submission of reports returned to sender for Unserved LOA and other correspondences the reason that the address is unknown related to audit Unserved correspondences related C Assessment Section -RDO / Compliance RDO/concerned office under concerned office under LTS INID LTS ARMD, CD Section LTCED

Collection Letters, etc.) collection enforcement (WDL WG. LTDO Cebu and Davao

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d The assigned RO of the concerned offices/sections identified under Item G.1.c

shall perform the necessary procedures applicable to the case, such as but not limited to:

I Require the CBL taxpayer to accomplish a registration update form; or

ii. Inform the CBL taxpayer of un-filed tax returns for compliance/updating;

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iii. Serve the unserved notices relative to audit and advise resurfaced taxpayer on what to do.

If the RO is in the process of preparing an audit report, PAN or FLD/FAN notices and proceed with the necessary course of action pursuant to existing issuances regarding policies and guidelines for assessment and collection. with the assessment based on the BEO rule or the best available document. the CBL taxpayer who resurfaced shall be served with all the unserved

N SLOZI NVT TI Nd 87 In casc an FLD/FAN has already been issucd, it shall be served and explained to the taxpayer. The taxpayer shall be informed of its right to contest the same within ten (10) days from date of receipt if it is not amenable to the assessment. Likewise, the taxpayer shall be informed that the prescriptive period to assess was suspended from the date the taxpayer was reported and approved as CBL and shall be lifted upon the service of such notice.

Iv Update the notices relative to collection enforcement and serve the same I to the resurfaced taxpayer, continue the enforcement of collection available for the settlement of the tax liabilitics. summary remedies and inform the resurfaced taxpayer of remedies

. The assigned RO shall prepare a Memorandum Report (Annex G), which shall be supported by any of the applicable documents listed below to corroborate the recommendation to un-tag the taxpayer as CBL:

i. Updated registration details and/or payment of tax liabilities; or

I. Documents showing the settlement of tax liabilities and completion of

other requirements, if any; or

ii. Waiver of Prescription in case taxpayer requested for compromise settlement, installment payment; or

IN. Agreement Form signed by the resurfaced taxpayer indicating the willingness to pay the assessed tax; and other pertinent documents.

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The aforementioned Memorandum Report shall be submitted to the Head of Office for approval.

case, the RO shall submit, instead of item (ii) above, a report/update on the In case of continuation of audit, the assigned RO may also recommend for the un-tagging of the CBL status of the taxpayer in IRIS-TRS and in the CBL taxpayer that may arisc from the evaluation of the pending CBL case. In such audit conducted. System without prejudice, however, to the deficiency taxes of the subject

2. The duly approved Memorandum Report (Annex G) of the assigned RO shall be ELTRD for Excise LT taxpayers for un-tagging of the CBL status of the taxpayer in IRIS-TRS. given to the Chief, CSS-RDO, Chicf, LTAD for Regular LT taxpayers and Chief.

3. In case of continuation of audit, the following procedures shall apply:

a. For LOA issued in eLAMS -- The Head/Assistant Head of Office shall remove "CBL" from the REMARKS column and follow the existing rules and regulations for continuation of audit.

b.For LOA issued in IRIS-CMS -

N Y A * Y SZ0Z4T NVT U82T If LOA was unserved - The Head/Assistant Head of Office shall lift the suspension of the case status, and assign the case to the original RO/GS. the cancellation of the previous LOA and replace it to re-assign the casc to Should any of the RO/GS is no longer with the Investigating Office, cause another RO/GS.

I If the LOA was served - The handling RO shall retrieve the case docket S from the RMD/AHRMD, whichever is applicable, and shall request for a 5t data fix in the IRIS-CMS-A from the ASD. The latter shall manage the

the case for the approval of the Chief of the Revicwing Office. assignment of the case to a RO/GS-Reviewer for the latter to be able to manage the case, including the initiation of the lifting of the suspension of

4.Based on the approved report of the assigned RO, the RDO/DC of the resurfaced CBL taxpayer shall immediately accomplish the Report of Resurfaced CBL Taxpayer (Annex H) to be submitted to AITEID thru email address aiteid@bir.gov.ph for posting by the latter to the BIR Website and updating of the same in the CBL System.

5. In order to un-tag the taxpayer as "CBL", the Chief, CSS-RDO, Chief, LTAD for Sourcc, Period Covered and Date Published. Regular LT taxpayers and Chief, ELTRD for Excisc LT taxpayers shall open the IRIS-TRS Taxpayer's Information module, enter the TIN of the taxpaycr, un-tick the box allotted for CBL and delete the information previously encoded per CBL

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I. ADMINISTRATIVE SANCTIONS

If irregularities in the registration process are discovered, resulting in the taxpayer being Officials and Employees. tagged as CBL, the concerned ROs/officials involved shall be subject to appropriate sanctions pursuant to the Revised Code of Conduct for the Bureau of Internal Revenue

The BIR shall also pursue other legal remedies provided by law and existing issuances against CBL taxpayers, as may be warranted.

IV. TRANSITORY PROVISIONS

A. Cases which arc in the hands of handling ROs whcre taxpayers could not be re-surface of the concerned taxpayers. located -- Handling ROs shall follow the prescribed provisions indicated hereof from reporting as CBL, assessments, if applicable, safekeeping and rcquired actions upon

B. Cases under the custody of different offices where involved taxpayers are already published as CBL -- Concerned RO and offices which have CBL case dockets under their custody shall prepare thc list of these CBL case dockets and transmit the same to the identified docket custodian in this Order.

V. REPEALING CLAUSE

are hereby repealed, modified or amended accordingly. Revenue Memorandum Circular No. 98-2010 dated December 8, 2010 and all other revenue issuances and/or portions thereof inconsistent with the provisions of this Order

V. EFFECTIVITY

All provisions of this Order shall take effect im

Re Zhissioner Of Ihternal p UMAZUL. JR. Revenue

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H

JAN 14 2025

Anmin unit . 39 TIME: 1: 20 Pm

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