Revenue Memorandum Order · RMO Audit / LOA / investigation
RMO No. 51-2024 Bureau of Internal Revenue • Independent research copy • Open source document ↗
Document type RMO
Number 51
Year 2024
Text quality ok REVENUE MEMORANDUM ORDER NO. 51-2024 issued on December 16, 2024,
suspends all audit and other field operations of the Bureau of Internal Revenue from
December 16, 2024 to January 12, 2025.
During this suspension period, the issuance of written orders to audit or investigate
taxpayers' internal revenue tax liabilities will be on hold, except in the following specific
scenarios:
a. Investigation of cases prescribing on or before April 15, 2024.
b. Cases involving tax evasion.
c. Processing and verifying estate tax returns, donor's tax returns, capital gains tax
returns, and withholding tax returns concerning the sale of real properties or shares
of stock, along with associated documentary stamp tax returns.
d. Examination and/or verification of internal revenue tax liabilities for taxpayers retiring
from business.
e. Monitoring of privilege stores (tiangge).
f. Other matters or concerns subject to specific deadlines.
Examiners and investigators shall utilize the suspension period for completing office-
based tasks and finalizing reports on cases where fieldwork has already been completed.
RMO No. 51-2024 suspends all audit and other field operations of the Bureau of Internal Revenue from December 16, 2024 to January 12, 2025. During the suspension, the BIR will not issue new written orders to audit or investigate taxpayers' internal revenue tax liabilities, except for enumerated scenarios: investigation of cases prescribing on or before April 15, 2024; tax evasion cases; processing and verification of estate tax, donor's tax, capital gains tax, and withholding tax returns for sales of real properties or shares of stock, together with associated documentary stamp tax returns; examination or verification of taxpayers retiring from business; monitoring of privilege stores (tiangge); and other matters subject to specific deadlines. Examiners and investigators are to use the suspension period to complete office-based tasks and finalize reports on cases where fieldwork has already been completed.
Purpose To suspend all audit and other field operations of the BIR from December 16, 2024 to January 12, 2025, place a hold on the issuance of written orders to audit or investigate tax liabilities subject to enumerated exceptions, and direct examiners and investigators to complete office-based tasks during the period.
In brief RMO No. 51-2024 suspends all BIR audit and other field operations from December 16, 2024 to January 12, 2025, holding the issuance of new written audit/investigation orders except for listed scenarios (e.g., tax evasion cases and processing of estate, donor's, capital gains, withholding, and documentary stamp tax returns). Examiners are to use the period for office-based tasks and finalizing reports on completed fieldwork.
Keywords suspension of audit and field operations written orders to audit or investigate prescription of cases tax evasion estate tax returns donor's tax returns capital gains tax returns withholding tax returns on sale of real properties or shares of stock documentary stamp tax returns taxpayers retiring from business privilege stores (tiangge) office-based tasks
Key points RMO No. 51-2024, issued December 16, 2024, suspends all audit and other field operations of the BIR from December 16, 2024 to January 12, 2025. During the suspension period, the issuance of written orders to audit or investigate taxpayers' internal revenue tax liabilities is on hold. Exceptions to the suspension include investigation of cases prescribing on or before April 15, 2024 and cases involving tax evasion. Processing and verification of estate tax, donor's tax, capital gains tax, and withholding tax returns relating to sales of real properties or shares of stock, along with associated documentary stamp tax returns, continue during the suspension. The suspension does not cover examination or verification of tax liabilities of taxpayers retiring from business, monitoring of privilege stores (tiangge), and other matters or concerns subject to specific deadlines. Examiners and investigators are directed to use the suspension period for completing office-based tasks and finalizing reports on cases where fieldwork has already been completed. Forms referenced Estate tax returns are referenced as subject to continued processing and verification during the suspension. Donor's tax returns are referenced as subject to continued processing and verification during the suspension. Capital gains tax returns are referenced as subject to continued processing and verification during the suspension. Withholding tax returns concerning the sale of real properties or shares of stock are referenced as subject to continued processing and verification. Documentary stamp tax returns associated with the covered transactions are referenced as subject to continued processing and verification. Tax types Internal revenue tax liabilities generally (the subject of audit or investigation orders). Estate tax (via estate tax returns covered by the processing/verification exception). Donor's tax (via donor's tax returns covered by the processing/verification exception). Capital gains tax (via capital gains tax returns covered by the processing/verification exception). Withholding tax (via withholding tax returns on sales of real properties or shares of stock covered by the exception). Documentary stamp tax (via associated documentary stamp tax returns covered by the exception). Affected taxpayers All taxpayers are generally affected: the BIR will not issue new written orders to audit or investigate internal revenue tax liabilities from December 16, 2024 to January 12, 2025, except in the enumerated scenarios. Taxpayers with cases prescribing on or before April 15, 2024 remain subject to investigation during the suspension period. Taxpayers with cases involving tax evasion remain subject to audit or investigation during the suspension period. Estate and donor's tax filers, and parties to sales of real properties or shares of stock, continue to be covered by processing and verification of the related estate, donor's, capital gains, withholding, and documentary stamp tax returns during the suspension. Taxpayers retiring from business may still be subjected to examination and/or verification of their internal revenue tax liabilities during the suspension. Operators of privilege stores (tiangge) remain subject to monitoring during the suspension period.