RMO No. 6-2026 — Amendments and Supplemental Guidelines Governing the Implementation of Revenue Memorandum Order (RMO) No. 1-2026 Digest | Full Text | Annex A | Annex B | Annex C | Annex D

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Bringing In Revenues for Nation-Building PILIPINAS BAGONG

MAR 0 4 2026

REVENUE MEMORANDUM ORDER NO. 0 0 6 - 2 0 2 6

SUBJECT :AMENDMENTS AND SUPPLEMENTAL GUIDELINES

GOVERNING THE IMPLEMENTATION OF REVENUE MEMORANDUM ORDER (RMO) NO.1-2026

TO :All Officials, Employees, and Others Concerned

I BACKGROUND

Following the issuance of RMO No. 1-2026, certain concerns and implementation matters have been identified with respect to its application, particularly on the consolidation of Electronic Letters of Authority (eLAs), including its scope, effects, and procedural implications.

procedures, and clarificatory guidelines to RMO No. 1-2026 to address such concerns and ensure the consistent, uniform, and orderly implementation of the consolidation framework and related audit reforms provided therein. Accordingly, this RMO is hereby issued to prescribe amendments, supplemental

H. AMENDMENTS

1. The following dates in RMO No. 1-2026 are hereby amended:

Non-Consolidation of VAT Audit Cases Automatic consolidation of all pending Deadline for filing written Requests for for Non-Consolidation is duly filed eLAs except where a written Request EVENT February 16, 2026 March 4, 2026 FROM March 20, 2026 March 13, 2026 TO

: ADMIN UNITIME: D A MAR 0 4 2026 E REVENU UREADS SFANTERNAN TC Last day of VATAS and LTVAU for purposes of winding up its operations Last day of audit operations for VAT Audit Sections (VATAS) and Large Taxpayers VAT Audit Unit (LTVAU) Automatic consolidation of all pending eLAs which were previously allowed to proceed separately pursuant to a Request for Non-Consolidation April 30, 2026 May 15,2026 May 4, 2026 May 15, 2026 May 18, 2026 May 29, 2026

2.Annex Aof RMO No.1-2026 is hereby revised as follows:

a) Item No. 7 under 1. Mandatory Case*, a. To be covered by Electronic Letter of Authority (eLA) shall now read as follows:

Selection Criteria Selection Code

xxx xxx xxx xxx xxx xxx

7. Taxpayers requesting for tax clearance whose gross sales of the immediately preceding year exceed Three Million TRC

retirement exceed Eight Million Pesos (P8.000.000.00) Pesos (P3.000.000.00) or whose gross assets upon

due to:

b. a. Death of the taxpayer: Taxpayers retiring from business: or C. Taxpayers undergoing merger/consolidation/split-

up/spin-off and other.types.of.corporate reorganizations

Revised Annex A of RMO No. 1-2026, reflecting all the amendments above, is attached in this Order as Annex A.

I. RULES ON CONSOLIDATION OF ASSESSMENT

A. ABSOLUTE PROHIBITIONS

1. No Consolidation at Final Decision on Disputed Assessment (FDDA) Stage -- No consolidation shall be allowed if any case has reached the FDDA stage. Cases that have reached the FDDA stage must proceed independently.

2. No Consolidation of Final and Executory Final Assessment Notice (FAN) -- No consolidation shall be allowed if a FAN has already become final, executory. and demandable. Once finality attaches, the assessment shall no longer be disturbed.

N ADMIN UNITIM T MAR 0 4 2026 REAS PFANTERNN REVENG s 3. No Consolidation of Cases Involving FAN Stage and Cases at Stages Prior stage shall not be consolidated with cases that remain at stages prior to the to Issuance of Preliminary Assessment Notice (PAN) - Cases at the FAN issuance of a PAN, whether with or without a Notice of Discrepancy (NOD). of the National Internal Revenue Code of 1997, as amended (Tax Code) FAN stage, in view of the remedies available to the taxpayer under Section 228 including the right to appeal to the Court of Tax Appeals. This rule is intended to prevent undue delay in the resolution of cases at the

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4. Exception: Allowed FAN-Level Consolidation -- Consolidation involving any F AN-stage case may be allowed only if:

a The FAN was validly issued and properly served; b. The protest period is still running, or a valid protest has been timely filed; C. The assessment has not yet become final and executory; d. All safeguards under Section III(C) of this Order are complied with; and e. Where a protest has already been filed, the Consolidated FAN is issued

before the lapse of the applicable one hundred eighty (180)-day period under Section 228 of the Tax Code.

Failure to satisfy any of the foregoing conditions shall preclude consolidation.

B. CONSOLIDATION CASES

this Order are not fully complied with, the cases shall proceed independently in The following rules shall guide Revenue Officers in determining whether consolidation may be effected. If the mandatory safeguards under Section III(C) of

accordance with their respective procedural stages.

1. Consolidation Prior to FAN Stage

No NOD No NOD Situation NOD Consolidate Action at 2 Issue Consolidated NOD; Preserve Mandatory Safeguards discrepancy discussion

3 rights (Discussion of Discrepancies); and Observe proper service of NOD. No NOD * Consolidate 2 1 Secure a Written Conformity to NOD NOD 2.Issue a Consolidated NOD expressly 3. Preserve taxpayer refuses to agree to the superseding the prior NOD; Consolidation (Annex B). If the consolidation, cases shall proceed independently; discrepancy discussion

rights (Discussion of Discrepancies); and 4. Observe proper service of NOD. NOD+NOD NOD Consolidate at 1. Secure a Written Conformity to Consolidation (Annex B). If the taxpayer refuses to agree to the

2.Issue a Consolidated NOD expressly 3. consolidation, cases shall proceed superseding the prior NODs; Preserve independently; discrepancy discussion

RECORDS MANAGEMETDIVISION BUREAU OFINTERNALREVENUE S 4 Observe proper service of NOD rights (Discussion of Discrepancies); and

MAR 0 4 2026

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No NOD PAN Stage proper completion NOD Elevate to PAN for after the of 2 The case at No NOD stage must first Secure a Written Conformity to undergo the discrepancy discussion process after the issuance and proper service of the NOD;

lower-stage case 3. Issue a Consolidated PAN expressly 5. A fresh fifteen (15)-day response 4. 6. Observe proper service; Secure a Waiver of Prescription, if Consolidation (Annex B. If the taxpayer refuses to agree to the consolidation, cases shall proceed period shall run from receipt of the necessary (Annex C) independently; superseding the prior PAN; Consolidated PAN; and

NOD+PAN Consolidate PAN at I 1. 2. Issue Consolidated PAN expressly 4. A fresh fifteen (15)-day response 3. 5 Secure a Written Conformity Observe proper service; Secure a Waiver of Prescription, if consolidation, cases shall proceed period shall run from receipt of the Consolidated PAN; and Consolidation (Annex B). If the taxpayer refuses to agree to the independently; superseding the prior PAN; to

necessary (Annex C)

BURFAUOFINTERNALREVENUE C VENT C DIVISION PAN+PAN Consolidate PAN at 2. Issue Consolidated PAN expressly independently; Secure a Written Conformity taxpayer refuses to agree to the Consolidation (Annex B). If the consolidation, cases shall proceed to

B MAR 0 4 2026 ADMINUNIT-1 TIME: 5:200 3. Observe proper service; 4. A fresh fifteen (15)-day response superseding the prior PANs; period shall run from receipt of the Consolidated PAN; and

5. Secure a Waiver of Prescription, if

necessary (Annex C)

2. Consolidation at FAN Stage

Situation Action Mandatory Safeguards No NOD + FAN No consolidation Not applicable.

NOD+FAN INo consolidationNot applicable.

PAN+FAN Proceed to I ThePAN-stage case mustfirst

after completion PAN-stage case consolidation at the FAN stage ofthePAN process for the 2. Upon completion of the PAN stage. consolidation at the FAN level may be effected, provided that: complete the fifteen(15)-day response period, unless the taxpayer submits a written response earlier.

b. The FAN has not become final c. The protest period is still a. The existing FAN was validly d and executory: running, or a valid protest has been timely filed; All safeguards under Section issued and properly served;

e. Where a protest has already been III(C) of this Order are complied with; and filed, the Consolidated FAN is

hundred eighty (180)-day period issued before the lapse of the one under Section 228 of the Tax Code.

3. If consolidation is pursued, the

following are required:

BY: BUREAUOF IN ADMINUNIT RM MAR 0 4 2026 NAGEMFNT DIVISION ERNALRFVFN TIME LE 5:2x0pm a. Written b.Waiver of Prescription (Annex e. A fresh thirty (30)-day protest d.Effect proper service; and c. Issuea Consolidated FAN Consolidation (Annex B); C); expressly superseding the prior FAN solely for purposes of 2026 period shall run from receipt of the Consolidated FAN consolidation under RMO No. 1- Conformity to

Failure to satisfy any of the foregoing conditions shall preclude consolidation. FAN+FAN Consolidation Consolidation shall be allowed only

may proceed at of the FAN stage through issuance a if: a. Both FANs have been validly issued and properly served;

Consolidated FAN b.Neither of the previously issued C. executory; The protest period is still running FANs has become final and

d. All safeguards under Section] been timely filed; for both, or valid protests have

III(Cof this Order are complied with; and e. Where protest has already been filed, the Consolidated FAN is

applicable one hundred eighty (180)-day period under Section issued before the lapse of the 228 of the Tax Code.

If consolidation is pursued:

b. Waiver of Prescription (Annex C. a Issue Written Consolidation (Annex B); C) aConsolidated Conformity FAN to

ABURFAULOEINTERNALRFVEN ECOROS MANAGEMET DIVISION MAR 0 4 2026 d.Effect proper service; and e. A fresh thirty (30)-day protest solely consolidation under RMO No. 1- 2026; period shall run from receipt of the Consolidated FAN. expressly superseding the FANs] for purposes of

AY 9W ADMIN UNIT520PM TIME Failure to comply with any of the foregoing requirements shall result in independent continuation of the cases.

3.Cases with FDDA

Any+ FDDA Situation No consolidation. Proceed independently. Action

C. MANDATORY SAFEGUARDS FOR FAN-LEVEL CONSOLIDATION

Consolidation involving any FAN-stage case shall not proceed unless ALL of the following are secured:

1. Written Conformity toConsolidation(Taxpayer Undertaking)

Applicable to Consolidated NOD, PAN, and FAN

The taxpayer must expressly agree in writing that:

b. The taxpayer voluntarily conforms to the issuance of a consolidated a.The identified audit case(s)/eLA(s) covering the same taxable period may be consolidated pursuant to RMO No. 1-2026;

c.Fresh response and/or protest periods shall run only upon proper service d. The conformity is procedural only, does not constitute an admission of notice that shall supersede the specifically identified prior notice(s) solely for consolidation purposes under RMO No. 1-2026; and receipt of the consolidated/superseding notice, in accordance with existing due process rules; and

liability, and does not waive substantive defenses or legal remedies available under law.

provided in Annex B of this Order. The prescribed template for the Written Conformity to Consolidation is

2.Waiver of Prescription

The Waiver of Prescription pursuant to Sections 203 and 222 of the Tax Code:

b. Must be signed by the taxpayer or a duly authorized representative. a. Must strictly comply with the requirements and form guidance under C. Must clearly specify the taxable period covered and a definite expiration RMO No.14-2016,Revenue Memorandum Circular No. 141-19, and related issuances; provided that the authorized representative must show a written authority which shall form part of the official record;

d While the taxpayer shall have the duty to retain a copy of the submitted date; and

should form part of the docket. waiver, a copy of the duly executed waiver showing BIR acceptance

A template of the Waiver of Prescription is hereto attached as Annex C.

3. Standard Supersession Clause at the NOD/PAN/FAN Level

If a Consolidated NOD/PAN/FAN is to be issued:

a. Any previously issued NOD/PAN/FAN covering the same taxable b. The Consolidated NOD/PAN/FAN must clearly identify the prior period shall be formally superseded for purposes of consolidation.

c.The Consolidated NOD/PAN/FAN must contain the following clause: the audit moving forward. NOD(s)/PAN(s)/FAN(s) being superseded and state that it shall govern

UREAUOFINTERNALREVENUE MAR 0 4 2026 ANACFMENT DIVISION "This Consolidated[NOD/PAN/FAN] supersedes the [NOD(s)/PAN(s)/FAN(s)] dated duly received on of RMO No. 1-2026, without prejudice to substantive rights and 2026, solely for purposes of consolidation under day

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M.

d. Proper service must be effected in accordance with applicable regulations. [NOD/PAN/FAN] for the taxable period concerned. remedies available under law. This Consolidated [NOD/PAN/FAN] shall constitute the operative

4. Proper Service

All consolidated notices must strictly comply with service rules under

nullity of the notices. Revenue Regulations No. 12-99, as amended. Failure in service may result in

5. No Regression Rule

Consolidation should not result in the reversal of a case to an earlier procedural stage in the statutory due process sequence. Accordingly:

a. A case that has reached the FAN stage shall not be reverted to the PAN

b. A case that has reached the PAN stage shall not be reverted to the NOD or NOD stage;

c. A validly served notice shall not be disregarded, nullified, or replaced stage; and except through a formal and properly documented supersession (or withdrawal, where appropriate) effected prior to finality.

be effected. Attached herewith as Annex D is the Consolidation Compliance Checklist, which shall guide Revenue Officers in determining whether consolidation may

IV. SUPPLETORY RULES ON VAT REFUND APPLICATIONS

During the wind-up and transition period of the VATAS and the LTVAU pursuant tc RMO No. 1-2026, the following rules shall govern the authority to receive and process VAT refund applications, to ensure continuity of service and clarity of jurisdiction:

A. Receipt of New VAT Refund Applications

be filed with and processed by the appropriate Revenue District Office or the Large March 31, 2026. Beginning April 1, 2026, all new VAT refund applications shall VATAS/LTVAU may continue to receive new VAT refund applications only until

Taxpayers Service having jurisdiction over the taxpayer.

ADMIN UNIT B MAR 0 4 2026 L H JREAU OAN said date. Thereafter, the case shall be endorsed to the appropriate reviewing office. said offices. Accordingly, all corresponding reports must be completed on or before All refund applications received before April 1, 2026 shall be fully evaluated by the

Y: FRNEN REVENGN Processing of Pending VAT Refund Applications received only until May 29, 2026. VATAS and LTVAU may continue to process VAT refund applications already

This Section is issued as a suppletory provision to clarify jurisdictional authority during the transition period and to ensure orderly turnover and uninterrupted processing of VAT refund applications.

V. EFFECTIVITY

This Order shall take effect immediately upon issuance.

VI. REPEALING CLAUSE

modified accordingly. All orders, memoranda, and issuances inconsistent herewith are hereby repealed or

CHARLITO MARTIN R. MENDOZA Commissioner of Internal Revenue

A-1

BUREAUOFINTERNALREVENUE RECORDS MANAGEMENTDIVISION

MAR 0 4 2026

BY N ADMIN UNIT1 TIME: 5:20pm