RMC No. 93-2021

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EUiftl IN,TEf,NAL KEVE fiUE

REPUBLIC OF THE PHILIPPINES


DEPARIMENT OF FINANCE
].R]
BUREAU OF INTERNAL REVENUE
orvrsro N
D
QUEZON CITY
AUG 0 6 2021

REVENUE MEMoRANDUM cTRCULAR No. %-2n21

SUBJECT: SUSPENSION OF THE RUNNING OF THE STATUTE OF


LIMITATIONS ON ASSESSMENT AND COLLECTION OF TAXES
PURSUANT TO SECTION 223 OF THE NATIONAL INTERNAL
REVENUE CODE OF 1997, AS AMENDED, DUE TO THE
DECLARATION OF ENHANCED COMMUNITY QUARANTINE
(ECQ) AND MODIFIED ECQ (MECQ) IN THE NATIONAL CAPITAL
REGION (NCR) AND OTHER AREAS OF THE COUNTRY.

TO: AII Internal Revenue Officers and Others Concerned

This Circular is being issued in light of the declaration of Enhanced Community


Quarantine (ECQ) and Modified ECQ (MECQ) in the National Capital Region (NCR) and
other areas ofthe countryl, thus restricting movement in the said areas and effectively barring
the service of assessment notices personally or by substituted service, and Warrants of
Distraint and or Levy, as well as Warrants of Garnishment, to enforce collection of deficiency
taxes.

prf{lantto Section 223 ofthe National Internal Revenue Code of 1997, asamended,
which provides that: "The running o-f the Statute of Limitations provided in Sectiotts 203 and
222 on the making of assessment and the beginning of distraint or levy or a proeeeding in court
for collection, in respect of any deficiency, shall be suspendedfor the period during which rhe
Commissioner is prohibited from making the assessment or beginning distraint or levy or a
proceeding in court and for sixty (60) days thereafter -xxx- ", vis-d-vis the definition of
"quarantine" under Revenue Regulations (RR) No. Il-2020, as amended by RR No. l2-2020,
the running of the statute of limitations for assessment and collection of deficiency taxes
is suspended in the affected jurisdictions while ECQ and/or MECQ is in effect, including
any extension/s thereof, and for sixty (60) days thereafter. The suspension of the running
of the Statute of Limitations shall apply with respect to the issuance and service of
assessment notices, warrants and enforcement, and/or collection of deficiency taxes.

In case of any future declarations of ECQ andior MECQ by the government on any
area/s of the country, thereby restricting movement in the said areals and effectively barring
the service of assessment notices, personally or by substituted service, and Warrants of
Distraint and or Levy, as well as Warrants pf Garnishment, to enforce collection of deficiency
taxes, the running of the statute of limitations for assessment and collection of deficiency taxes
shall likewise be suspended in the affected jurisdictions while ECQ and/or MECQ is in effect,
and for sixty (60) days thereafter.

) IATF Resolution No. 130-A dated Jply 29.2021 and IATF Resolution No. I3l dated August 5,2021. Forr{'JCR. the ECQ is
from06August202l to20August202l.
,,* f I

b
This Circular shall apply nationwide on areas placed under ECQ and MECQ.

All Revenue Officials are hereby enjoined to give this Circular as wide publicity as
possible.

tr4*^*_
CAESAR R. DULAY
ilr 044413
Commissionetof Internal Revenue

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