BIR allows exporters in transition VAT refunds

Export-oriented enterprises may claim refunds for qualified value-added tax payments incurred while waiting for their zero-rating certification, the Bureau of Internal Revenue said.

The BIR issued Revenue Memorandum Circular No. 96-2026 on 7 September, clarifying the treatment of input VAT for qualified export-oriented enterprises during the transition to the new VAT zero-rating certification system.

Amends VAT refund guidelines under RMC No. 37-2025

The circular amends the VAT refund guidelines under RMC No. 37-2025 and covers VAT paid on eligible local purchases and importations attributable to qualified zero-rated sales beginning 28 November 2024 and before the enterprise received its certification from the Department of Trade and Industry-Export Marketing Bureau.

To qualify, the certification must have been issued within the prescribed transition period, which ended on 31 December 2025.

“Export-oriented enterprises received their VAT zero-rating certifications on different dates during the transition period. We are clarifying how VAT incurred while these certifications were being processed should be treated so qualified export-oriented enterprises will have a clear basis for their refund claims,” BIR Commissioner Charlito Martin R. Mendoza said.

Refund subject to Section 112 of National Internal Revenue Code

The refund remains subject to Section 112 of the National Internal Revenue Code, as amended. Enterprises must provide proper documentation and establish that the input VAT being claimed is directly attributable to qualified zero-rated sales.

The BIR said VAT that has already been reimbursed, credited, adjusted, recovered from suppliers or otherwise used cannot be claimed again as a refund.