REVENUE MEMORANDUM ORDER NO. 006 – 2026
This report summarizes the updates provided in Revenue Memorandum Order (RMO) No. 006-2026, issued on March 4, 2026. This RMO amends and provides supplemental guidelines for RMO No. 1-2026, specifically regarding the consolidation of Electronic Letters of Authority (eLAs) and audit reforms.
1. Updated Implementation Timeline
The following deadlines from RMO No. 1-2026 have been officially amended:
| Event | Original Date | New Date |
| Deadline for filing written Requests for Non-Consolidation of VAT Audit Cases | February 16, 2026 | March 13, 2026 |
| Automatic consolidation of all pending eLAs (unless Non-Consolidation request filed) | March 4, 2026 | March 20, 2026 |
| Last day of audit operations for VATAS and LTVAU | April 30, 2026 | May 15, 2026 |
| Automatic consolidation of pending eLAs previously allowed to proceed separately | May 4, 2026 | May 18, 2026 |
| Last day of VATAS and LTVAU winding-up operations | May 15, 2026 | May 29, 2026 |
2. Revised Selection Criteria for Mandatory Cases
Taxpayers requesting tax clearance are covered by an eLA under the following updated thresholds and conditions:
- Gross Sales: Exceeding ₱3,000,000.00 in the immediately preceding year.
- Gross Assets: Exceeding ₱8,000,000.00 upon retirement.
- Applicable Scenarios: Death of the taxpayer, retirement from business, or corporate reorganizations (mergers, consolidations, split-ups, spin-offs).
3. Rules on Assessment Consolidation
The RMO establishes strict guidelines for when tax assessment cases can or cannot be consolidated.
Absolute Prohibitions
Consolidation is strictly prohibited in the following stages:
- FDDA Stage: If any case has reached the Final Decision on Disputed Assessment (FDDA) stage.
- Final/Executory FAN: If a Final Assessment Notice (FAN) is already final, executory, and demandable.
- Stage Mismatch: Cases at the FAN stage cannot be consolidated with cases at stages prior to a Preliminary Assessment Notice (PAN).
Mandatory Safeguards for Consolidation
For allowed consolidations, the following “Mandatory Safeguards” must be met:
1. Written Conformity: The taxpayer must expressly agree in writing to the consolidation.
The prescribed template for the Written Conformity to Consolidation is provided in Annex B.
2. Waiver of Prescription: A valid Waiver of Prescription must be executed.
A template of the Waiver of Prescription is hereto attached a s Annex C.
3. Supersession Clause: Consolidated notices (NOD, PAN, or FAN) must contain a standard clause formally superseding prior notices.
4. Proper Service: All consolidated notices must strictly comply with service requirements prescribed under RR no. 12-99, as amended; otherwise, such notices are null.
5. No Regression Rule: Consolidation cannot revert a case to an earlier procedural stage (e.g., a FAN stage case cannot be reverted to the PAN or NOD stage).
Attached herewith as Annex D is the Consolidation Compliance Checklist, which shall guide Revenue Officers in determining whether consolidation may be effected.
4. Transition Rules for VAT Refund Applications
To ensure continuity during the phase-out of the VAT Audit Sections (VATAS) and Large Taxpayers VAT Audit Unit (LTVAU), the following rules apply:
- New Applications: VATAS/LTVAU will stop receiving new applications after March 31, 2026.
- Jurisdiction Shift: Starting April 1, 2026, new applications must be filed with the appropriate Revenue District Office (RDO) or Large Taxpayers Service (LTS).
- Pending Applications: VATAS/LTVAU may continue processing existing pending applications only until May 29, 2026.
5. Effectivity
This order took effect immediately upon its issuance on March 4, 2026.