RR No. 8-2025: Implementing Sections 112(C) and 135-A of the National Internal Revenue Code of 1997, as Amended by Section 9 and 11 of Republic Act No. 12066 on the Procedures in the Resolution of Requests for Reconsideration on the Denial of Claims for Refund

Key points

1. Coverage. It covers full or partial denials of refund claims under Sections 112(A) and (B) and 135-A for applications filed on or after April 1, 2025.
2. Scope of the request. Requests are limited to questions of law. Factual issues raised, new evidence, and legal questions already addressed in the denial notice are not allowed, and only documents previously attached to the application may be submitted.
3. Deadlines and finality. The request must be filed within fifteen (15) days, and the Processing Office acts within fifteen (15) days from actual receipt. A late denial request is not received, and the denial becomes final after the period lapses. No supplemental pleading or second request is allowed.
4. Where to file. Denials within the National Office, including those signed by the Assistant Commissioner of the Large Taxpayers Service, go to the Appellate Division, with the Office of the Commissioner approving. Denials signed by the Regional Director go to the Legal Division of the Revenue Region concerned, with the Regional Director approving.
5. Contents and attachments. The request needs a prescribed capitalized title, a claim description with the TVN number and amounts, date of receipt of the denial, and statement of facts and errors of law. It attaches an authority to file, the stamped application, the denial notice, the checklist of mandatory requirements and other pertinent documents. Non-compliance is ground for outright denial.
6. After the decision. A granted refund is processed within twenty (20) days from the decision. The claimant may withdraw the request before it is resolved, and may appeal to the CTA within thirty (30) days from receipt of the decision or lapse of the 15-day period.

Who is affected

• Taxpayer-claimants of VAT refund under Sections 112(A) and (B)
• Suppliers claiming Excise Tax refund under Section 135-A

Deadlines and effectivity

• Applies to refund applications filed on or after April 1, 2025
• Request for reconsideration: within fifteen (15) days
• Decision: within fifteen (15) days from receipt
• Appeal to CTA: within thirty (30) days