The Bureau of Internal Revenue (BIR) issued Revenue Regulations (RR) No. 4-2026 to prescribe the guidelines and procedures for the availment of a one-time abatement of taxes and penalties for eligible micro taxpayers. The regulations implement Section 204(D) of the Tax Code, as amended, which authorizes the reduction or abatement of tax liabilities and penalties on grounds such as unjustly assessed taxes or administrative considerations.
Coverage and eligibility
The abatement applies to all delinquent accounts and assessments, whether preliminary or final, disputed or not, as of Dec. 31, 2025, including open stop-filer cases. To qualify, the taxpayer must be classified as a micro taxpayer, with annual gross sales or business receipts not exceeding P3,000,000.
The following cases of micro taxpayers with delinquent or assessed basic tax or penalties of not more than P80,000 may apply for abatement:
• Delinquent accounts;
• Cases under administrative protest pending in the Revenue Regional Office, Revenue District Office, Legal Service, Appellate Division, Collection Service, Enforcement Service, and other offices in the National Office;
• Tax cases being disputed before the Department of Justice and the courts, including the Court of Tax Appeals and the Supreme Court, provided such cases have not yet become final and executory;
• Tax collection cases filed with the courts;
• Cases with pending applications for compromise settlement under the prevailing compromise regulations;
• Cases with pending requests for abatement under previous BIR issuances;
• Criminal violations, except those already filed in court and other cases excluded under the regulations;
• “Accounts Payable or Due to BIR” accounts duly recorded or acknowledged by the taxpayers in their books of accounts; and
• No basic tax due, but the threshold amount involves penalties due.
The P80,000 threshold shall refer to the total basic tax liabilities and/or penalties arising from violations of the Tax Code, as amended, covering all the above-mentioned cases for a taxable year.
Application requirements and payment
Micro taxpayers intending to avail of the abatement must file an application using the prescribed form with the Revenue District Office having jurisdiction over the taxpayer. The application must indicate the specific tax type and taxable period covered and include proof of payment of the required amount due under the abatement program.
Upon acceptance of the application, the taxpayer is required to pay the amount of P5,000 abatement fee using BIR Form No. 0605, either electronically or manually. The abatement fee shall be paid within 5 working days from the filing of the application. In case of withdrawal of the application, the abatement fee shall not be refundable, but shall be applied as partial payment to the taxes or penalties sought to be abated.
Proof of payment shall be submitted to the RDO within five working days from the date of payment. Failure to submit the proof of payment within the required period automatically voids the application, without prejudice to re-filing the same within the availment period.
Availment process
The following guidelines shall apply to the availment of the one-time abatement program:
• Qualified taxpayers may avail of the one-time abatement until Dec. 31, 2026, unless extended by the Secretary of Finance upon recommendation of the Commissioner of Internal Revenue.
• A Certificate of Availment shall be issued by the concerned Revenue District Office within five working days from receipt and verification of the proof of payment.
• The Certificate of Availment serves as proof of the taxpayer’s availment of the abatement and compliance with the requirements of the regulations.
• Taxpayers with pending appeals of final decisions on disputed assessments before the Office of the Commissioner must first secure the necessary approval before the issuance of the Certificate of Availment.
Effectivity
RR No. 4-2026 shall take effect 15 days after its publication on the BIR website on July 22, 2026.
Please be guided accordingly.
Source:
P&A Grant Thornton
Certified Public Accountants