REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE
BUREAU OF INTERNAL REVENUE
Quezon City

April 5,2018

OPERATIONS MEMORANDUM NO. *S[ g- S4"S3

SUBIECT : Consolidated Guidelines on the Reassignment/Referral of Cases for Continuation

of Tax Audit/h-ivestigation and the Correspor-rding Issuance of Letter of Authority
(LOA) and Memorandum of Assignment (MOA) relative thereto.
TO All I.temal Revenue officials and Revenue officers Concerned

Section 235 of the National Internal Revenue Code (NIRC), as amended, provides, among
others, that for income tax purposes, examinafion and inspection of the books and records of i
taxpayer shall be made only once in a taxable year, except in certain cases specifically meltioled
under the aforesaid section of the NIRC. Thus, as a general policy, only one Letter of Autirority (LOA)
is issued for each taxable year or period covering the audit/investigation of all intenal revenue tax
liabilities of tl-re taxpayer, except rt'hen a specific tax type had been previously examined (e.g. audit of
VAT Liabilities under the VAT Audit Program, audit of VAT arising from clairn for tax rJfund/tax
credit certificate, etc.)
Furthermore, Section 13 of the NIRC states that a Revenue Officer (RO) assigned to perform
assessment functions in any diskict may, Pursllant to a LOA issued by the Revelue Regional Director,
examine taxpayers within the jurisdiction of the district in order to collect tire correct amount of tax,
or to recommend the assessment of any deficiency tax due in the same mamer that tl-re said acts could
have been performed by the Revenue Regional Director himself.
In line w'ith these provisions and existing policies, particularly in cases where there are
reassigtrrneuts or referrals of cases to another Revenue Officer (RO)/Group Supervisor (GS) due to
kansfer to another office, retirement or resignation, authorized leave sucli as maternity and sfudy
ieave, prolonged absence/unauthorized leave, or other reasons where the original RO/CS hancllilg
the case cannot continue flre tax audit/investigation, ail Revenue District Officers (RDOs) are hereb|
required to cause the cancellation of the original LOA and the issuance of another LOA to replace flre
original to be signed and approved by the Regional Director (RD).
In requestiug for the LOA replacement, aside flom the name of the new RO/GS, the lumber
of the cancelled LOA sl-rall be encoded and the appropriate reason (e.g. resignatio. of the RO/GS,
retiremeut of the Ro/GS, transfer of tl-re RO/GS to another district officl, etc.fmust be selectecl from
tire list of reasons for LOA replacement that will be displayed in the "Elech-o.ic Letter of Authority
Request Data Entu'y" screen. The said information is necessary so that the replaceme.t LOA for
the
reassignment of the case to another RO/GS will have a lotation at tl-re bottornas follows:
"This is a replacement of Letter of Authority No.
==- datecl
for flre continuation of audit of irerein tax liabilities for tl-re taxable
.
i-reriocl from -=--to_--=- .trising frorn the reassignmerrt of case dne
to
Please see attachec-l Job Aicl for the step b1, step procedures on the replacemelt of LOA i. the
elech'onic Letter of Authority N,ionitoring System (eLAMS).

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 However, in case of promotion/change of designation of the RO/GS handling the case who
are still assigned in the'same district office, the original RO/GS n ill continue the initial investigation.
For investigating offices nhere the Case Management System (CMS) under electronic Tax
Information System (eTIS) rvas rolled out, the ACIR, Large Taxpayers Service (LTS)/ RDOs under
Revenue Region (RR) No. B-Makati City shall request for the closure of the previous LOA from the
Adminislrative Systerns Division (ASD) under the Information Systems Project Management Service
per-rding the enhancement of eTIS-CMS. Afterwards, the I{ead/RDO shall cause the issuance of a new
LOA to be signed and approved by the ACIR/RD for continuation of audit. On the other hand, all
pending cases issued through eLAMS that require tl-re replacement of LOA shall be font,arded by the
Head-LT/RDO to ACIR/RD for cancellation of the said LOA in eLAMS. Thus, a new LOA will be
issueel through eTIS-CMS to replace the cancelled LOA under eLAMS.
Further, in all instances, a ietter stating the details of the original LOA such as case nurnber
and date of issuance shall be prepared, issued and sent to the concerned taxpayer to inform of the
cancellation of the old LOA and the continuance of audit through the issuance of the new LOA.
These above-stated policies and procedures shall apply to the following:
1. Reassignment of cases to another RO/GS while the tax audit/investigation is still
on-going;
2. Compliance of review findings prior to issuance of the Preliminary Assessment
Notice (PAN) on returned cases by the reviewing office;
3. Response to the PAN;
4. Reinvestigation cases [Protest on Final Assessment Notice (FAN) issued];
5. Compliance on revieu, findings on the recommendation for issuance of Final
Decision on Disputed Assessment (FDDA); and
6. Taxpayer transfers registuation but with on-going investigation.

However, for cases enumerated on the above item nos. 2 to 5 and the originai RO/GS are still
assigned in the RDO, an electronic Memorandum of Assignment (eMOA) shall be issued by the RDO
for audit traii purposes ordy.
In view of the foregoing, all pending cases which are still under tax audit/investigatiorl
ir-rcluding those rt hich were returned by tJre reviewing office for compliance of certain documentary
requirements and were reassigned to another RO/GS through an eMOA shall be covered by a
replacement of a new LOA following tl-re policies and guidelines and procedures set forth herein.
Notwithstanding the issuance of a new LOA, all concerned shall submit flre report on these
ithin ten (10) days from payment of deficiency taxes and for cases recommended for
cases rt
assessment, within six (6) rnonths prior to the prescription date.
For your guidance and immediate compliance.

NEL BALLA
pu 101-Ier

l-1

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