RMC No. 84-2026: BIR Answers FAQs on the One-Time Tax Abatement Program for Micro Taxpayers

RMC No. 84-2026 is the BIR’s clarificatory circular for RR No. 4-2026’s one-time abatement program for micro taxpayers, issued in question-and-answer format around July 2026. It does not create new eligibility rules — gross sales below P3,000,000 and outstanding basic tax and/or penalties of up to P80,000 per taxable year, for qualified cases existing on or before December 31, 2025, still apply. Instead, it resolves specific scenarios the base regulation left unclear: pending compromise applications, multiple problem years, partial payments, and what a Certificate of Availment actually proves.

What is RMC No. 84-2026 and why did the BIR issue it? #

RMC No. 84-2026 clarifies RR No. 4-2026 through a question-and-answer format, addressing taxpayer qualification, documentary requirements, filing procedures, payment of the one-time abatement fee, covered tax liabilities and penalties, application timelines, and other implementation issues that surfaced once RDOs started processing applications. It also supplies worked examples to help taxpayers determine eligibility on their own.

The circular exists because RR No. 4-2026, issued in June 2026, set out the abatement program’s basic framework but left several practical questions unanswered — questions this site’s companion guide to RR No. 4-2026 covers only at a high level. RMC No. 84-2026 fills that gap. According to reporting from the Philippine Daily Inquirer, the clarification matters because uncertainty over qualifications, documents, and payments could otherwise cause eligible applications to be denied outright.

How does RMC No. 84-2026 treat a pending compromise or abatement application? #

A micro taxpayer who already has a compromise settlement request pending with the BIR is not locked out of the new abatement program. RMC No. 84-2026 treats a pending compromise application — even one still moving through internal BIR review — as one of the eligible case types, so the taxpayer does not have to withdraw or resolve that older request first before applying.

Specifically, cases with a pending request for Compromise Settlement that are under evaluation by the Technical Working Group–National Evaluation Board (TWG-NEB), the Regional Evaluation Board (REB), or the NEB and REB directly, fall within the categories the RMC recognizes as eligible for the one-time abatement — so long as the taxpayer independently meets the micro-taxpayer gross sales test and the P80,000 per-year liability cap. This matters in practice because a compromise application can sit in the evaluation pipeline for months; RMC No. 84-2026 means that wait does not by itself disqualify the taxpayer from the faster, cheaper abatement route.

How are multiple taxable years and partial payments handled? #

A taxpayer with unresolved liabilities spanning more than one taxable year does not get to bundle them into a single application — RMC No. 84-2026 confirms the One-Time Abatement Application Form is filed one per qualifying taxable year, so multiple problem years mean multiple separate P5,000 fee payments, one per year covered.

The same per-case logic carries over to what happens when an application does not go through:

In other words, the P5,000 is never simply lost — even a denied or withdrawn application converts that payment into a credit against the taxpayer’s underlying liability, rather than an added cost on top of it.

What can get an application denied, and what does the Certificate of Availment mean? #

RMC No. 84-2026 spells out concrete, avoidable reasons an application can fail, and it clarifies that approval ends with a specific document — the Certificate of Availment — that functions as the taxpayer’s proof the case is closed, not merely that a fee was paid.

Grounds for denial identified in the circular include:

• Failing to specify the tax type and the basic tax amount due (excluding interest) for each case covered by the application
• Failing to submit proof of payment of the P5,000 abatement fee within the prescribed period, which automatically voids the application

Once an application clears review and the fee is settled, the RDO issues a Certificate of Availment. As reported by mpm.ph in its coverage of the program, “the RDO will issue a Certificate of Availment within 5 working days from receipt and verification of the proof of payment. Such certificate shall serve as proof of availment of abatement and the closure of the case.” That closure language is what distinguishes the certificate from a simple receipt — it is the taxpayer’s documentary evidence, going forward, that the specific liability was legally discharged under the program rather than merely paid down.

Frequently asked questions #

What is RMC No. 84-2026? #

RMC No. 84-2026 is a Revenue Memorandum Circular that clarifies RR No. 4-2026, the one-time abatement program for micro taxpayers, in a question-and-answer format covering taxpayer qualification, documentary requirements, filing procedures, payment of the abatement fee, covered liabilities, application timelines, and other implementation issues, with examples to guide eligibility.

If I already have a pending compromise settlement application, can I still apply for the abatement? #

Yes. RMC No. 84-2026 lists a pending request for compromise settlement — including one still under evaluation by the Technical Working Group, the National Evaluation Board, or a Regional Evaluation Board — as one of the case types eligible for the one-time abatement, provided the taxpayer otherwise qualifies as a micro taxpayer and the liability meets the P80,000 threshold.

Do I need to file a separate application for each taxable year with an outstanding liability? #

Yes. RMC No. 84-2026 confirms that the One-Time Abatement Application Form is filed on a per-taxable-year basis, so a micro taxpayer with unresolved liabilities in more than one year files a separate application, and pays a separate P5,000 abatement fee, for each qualifying year.

What happens to my P5,000 abatement fee if my application is denied or withdrawn? #

The P5,000 abatement fee is non-refundable. RMC No. 84-2026 clarifies that if an application is withdrawn or denied, the fee already paid is not returned but is instead applied as partial payment against the basic tax or penalties the taxpayer was seeking to have abated.

What can cause the BIR to deny my abatement application? #

RMC No. 84-2026 identifies specific grounds for denial, including failing to specify the tax type and basic tax amount due, excluding interest, for each covered case, and failing to submit proof of payment of the P5,000 fee within the prescribed period, which automatically voids the application.

What does the Certificate of Availment prove once my application is approved? #

The Certificate of Availment is the BIR’s official confirmation that a covered case has been closed under the program. The RDO issues it within five working days of receiving and verifying proof of payment, and it serves as the taxpayer’s proof that the covered liability and its penalties have been abated and the case is closed.

Summary #

RMC No. 84-2026 does not change who qualifies for the RR No. 4-2026 abatement — it changes how the edge cases get handled. A pending compromise settlement request does not disqualify a taxpayer; liabilities across multiple taxable years each need their own application and their own P5,000 fee; a denied or withdrawn application still converts its fee into partial payment rather than a sunk cost; and a Certificate of Availment, issued within five working days of a verified payment, is the document that proves a case is actually closed. For the underlying eligibility rules and application steps, see RR No. 4-2026: One-Time Tax Abatement for Micro Taxpayers, and for how this program compares to the BIR’s separate reduced compromise penalty track, see RR No. 6-2024: Reduced Compromise Penalty for Micro and Small Taxpayers and RMO No. 7-2015: Compromise Penalties Explained.