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On 30 March 2020, in light of the declaration of a State of National Emergency, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular No. 34-2020 (RMC 34-2020) to suspend the running of the statute of limitations on the period to assess and collect taxes under Section 203 and 222 of the National Internal Revenue Code.

The BIR explains that the current situation has prevented the Commissioner of Internal Revenue and/or his authorized representatives from making and serving the required notices and warrants for the assessment and collection of deficiency taxes.

The suspension of the statute of limitations under RMC 34-2020 is for a period commencing on 16 March 2020 until the State of National Emergency is lifted and for sixty (60) days thereafter. The suspension also applies to the issuance and service of assessment notices and warrants and the enforcement and/or collection of deficiency taxes.


Kristine Anne Mercado-Tamayo is a partner in Quisumbing Torres’ Tax Practice Group. She has 13 years of experience assisting clients on tax issues, involving corporate restructuring, mergers and acquisitions and other cross-border transactions. Kristine advocates on clients' behalf in controversies involving disputed tax assessments, representing clients before the Bureau of Internal Revenue. Kristine Anne obtained her Doctor of Law degree from the Ateneo de Manila in 2005. She is cited as a Next Generation Partner in Tax by the Legal 500 Asia Pacific for 2020. She has been recently appointed as Chairperson in Tax and Financial Services Committee of the European Chamber of Commerce of the Philippines.


Deodar Bautista is an associate of Quisumbing Torres’ Tax Practice Group. He has experience in assisting in Bureau of Internal Revenue tax audit investigations for companies in the manufacturing, advertising and business process outsourcing industries. He also has handled cases involving high-value tax refund claims.