What to check when you receive a BIR LOA or eLA, including audit authority, scope, receipt records and the response to document requests.
Direct answer
Record when the LOA or eLA was received, check its authority and scope, and organize the response. Raising an objection does not, by itself, stop the audit or later deadlines.
Preserve the authority and service record
Keep the complete authority, covering letter, acknowledgment and earlier audit authority. Identify the taxpayer, periods, tax types, officers and issuer. Check the applicable delegation and issuance rules; do not assume every RDO may sign or that a universal 30-day lapse rule applies.
Check replacements and assignments
RMC No. 14-2026 explains that the Single-Instance Audit Framework is prospective. A valid older authority is not invalid simply because the new framework exists. A replacement eLA can preserve continuity within the relevant conditions, including the same taxpayer, period and scope. Review the chain of authority when personnel change.
Identify the actual defect and distinguish it from a change permitted by the rules. Put the objection on record while continuing to protect response and protest deadlines.
Control the production process
| Workstream | Practical record |
|---|---|
| Authority | Original and replacement eLAs, assignments and receipt dates. |
| Scope | Covered entities, periods and taxes matched against requests. |
| Evidence | Indexed copies, reconciliations and a designated custodian. |
| Communications | One response register with requests, answers and delivery proof. |
| Management | Issue owner, escalation date and material-exposure assessment. |
Coordinate document production so the information is accurate and responsive. Distinguish originals from copies, avoid conflicting departmental explanations and preserve the historical records without alteration.
Do not confuse audit response with protest
An LOA authorizes examination; it is not the final assessment. A NOD, PAN, FLD/FAN and decision each require a fresh review. For reinvestigation of an FLD/FAN, failing to submit relevant supporting documents within the applicable 60-day period is not merely an automatic conversion into reconsideration. See the formal protest guide before choosing that remedy.
Settlement and further proceedings
Compromise requires statutory eligibility and approval; it is not a routine entitlement. Section 204 excludes criminal violations already filed in court and those involving fraud from its criminal-compromise authority. Other conditions and the particular case still matter. A later collection measure or criminal referral should be assessed separately from the original audit response.
Related assistance
For the next step, see audit defense, authority defects. Engagement depends on conflict checking and an agreed scope.
Sources and further reading
Important
This article provides general information, not advice on a particular matter. The applicable law, documents, procedural events and facts must be checked. Reading it does not create an attorney-client relationship.
Topics covered:
BIR letter of authorityLOA response PhilippinesBIR audit defensetax assessment PhilippinesPAN FAN protestNIRC
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