Revenue Memorandum Circular · RMC
RMC No. 82-2022
To clarify the service of the electronic Letter of Authority (eLA) to the taxpayer within the 30-day period from its date of issuance pursuant to RAMO No. 1-2000, in light of the amendment of RAMO No. 1-2000 by RAMO No. 1-2020 which deleted the provision on serving the eLA.
- Document type
- RMC
- Number
- 82
- Year
- 2022
- Text quality
- Not specified
Document text
Reference copy · verify against the official sourceRMC No. 82-2022 (June 30, 2022) clarifies the service of the electronic Letter of Authority (eLA) following RAMO No. 1-2020's amendment of RAMO No. 1-2000, which deleted the provision on serving the eLA (including the 30-day reference). Because the timeline for service of the eLA is no longer explicitly provided, Revenue Officers must serve the eLA immediately upon issuance/assignment, and the entire audit process must still be completed within 180 days for RDO cases or 240 days for LT cases from the eLA's date of issuance. Non-observance is gross neglect of duty subject to administrative sanctions under RMO No. 53-2010. An eLA that remains unserved upon the Circular's effectivity or is served beyond the 30-day period remains valid and enforceable, provided the 180-day/240-day audit completion period has not expired; taxpayers may not refuse service or question the eLA's validity on the ground of late service.