REVENUE MEMORANDUM CIRCULAR (RMC) NO. 037-2025
RMC 37-2025, cover claims for VAT refund under Section 112(A) and (B) of the Tax Code, except those pursuant to a writ of execution by the Courts, that are filed on April 1, 2025, and thereafter. This provision states that the time frame for processing and granting of claims for VAT refund is 90 days, counting from the date of submission of the certified true copies of the invoices or official receipts and other support documents up to the release of the payment for the approved amount of the refund. The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular No. 37-2025 on April 10, 2025, to implement this provision.
Taxpayers applying to claim unutilized input taxes attributable to VAT zero-rated sales should file their “Application for VAT Credit/Refund Claims” (BIR Form No. 1914) at the VAT Credit Audit Division (VCAD) in the national office.
The types of VAT zero-rated sales covered here include:
- direct export sales of goods, regardless of the percentage of export sales to total sales;
- direct export sales of services, regardless of the percentage of export sales to total sales;
- sale of goods to persons engaged in international shipping or international air transport operations;
- services rendered to persons engaged in international shipping or international air transport operations; and
- transport of passengers and cargo by domestic air or sea vessels from the Philippines to a foreign country.
On the other hand, taxpayer-claimants not covered by the above provision should file their VAT refund claims at the VAT Audit Section (VATAS) of the Assessment Division of Regional Offices, the respective Revenue District Office if without VATAS, or the Large Taxpayers VAT Audit Unit of the Large Taxpayers Service.
Applications for VAT refund should be filed at these offices for the following types of zero-rated sales:
- Sale of raw materials or packaging materials to a non-resident buyer for delivery to a resident local export-oriented enterprise to be used in manufacturing, processing, packing or repacking in the Philippines of the said buyer’s goods;
- Processing, manufacturing or repacking goods for other persons doing business outside the Philippines whose goods are subsequently exported;
- Sale of power or fuel from renewable energy sources;
- Those with effectively zero-rated sales for the following: sale of goods and services to an export-oriented enterprise (EOE); sale of goods to bonded manufacturing warehouses of EOEs; sales of goods and services to persons or entities covered under special laws or international agreements; and sale of goods and services to registered business enterprises covered under Title XIII of the Tax Code; and
- Taxpayers whose VAT registration has been cancelled or changed in the VAT registration status to non-VAT but with accumulated unutilized input taxes
RMC 37-2025 states that VAT refund claims must be filed in person at the designated processing office for validation of required documents. Only complete applications will be accepted and processed.
| Description | Tax Treatment |
| EOE that attained 70% threshold from the preceding taxable year in case the local suppliers passed on the VAT on the local purchases of goods directly attributable to the former’s export activity for the immediately succeeding year despite securing VAT zero-rating certificate | No refund of input VAT shall be allowed. In such cases, the qualified exporter may contest the same and/or resolve with:the local supplier for the reimbursement of the VAT paid, if any, orconvert the transaction from 12% VAT to VAT at zero percent. |
| The Export Marketing Bureau (EMB) of the Department of Trade and Industry. | EMB Will:Accept applications of EOEs for VAT zero-rating on their local purchases; andVAT exemption on their importations and certify the direct export sales of qualified taxpayer-claimants The BIR will verify the export sales of the taxpayer-claimant based on the certification issued by the EMB. |
| EOEs that have attained the 70% export threshold from the preceding taxable year but failed to secure certification from the EMB. | Not allowed for VAT refund covering the immediately succeeding year. However, the unutilized input VAT may be carried forward to the subsequent taxable quarters and can be utilized against future VAT liabilities. |
| EOE did not meet 70% export threshold and is claiming refund for zero-rated local purchases in the succeeding year | Must submit EMB notification confirming the threshold was not met. This proves that the succeeding year’s local purchases are not qualified for VAT zero-rating and are subject to 12% VAT. |
| Purchases from Registered Business Enterprises (RBEs) covered under RR No. 9-2025 | No input VAT shall be claimed until the VAT is paid on purchases from RBE-sellers. The following documents are required for the local buyers of RBEs: Sales invoice issued by the RBE showing the amount of VAT on local sales and copy of the corresponding duly filed BIR Form No. 1600VT or BIR Form No. 0605, whichever is applicable. |
For VAT refund claims where the period covered starts from April 1, 2025, taxpayer-claimants should take note of the following rules:
RMC 37-2025 also includes the checklist of documents to be submitted upon filing of the application for VAT refund. The circular takes immediate effect.