THE Bureau of Internal Revenue (BIR) will allow export-oriented enterprises (EOEs) to claim refunds on value-added tax (VAT) passed on to them while awaiting the issuance of their VAT zero-rating certifications from the Department of Trade and Industry -Export Marketing Bureau (DTI-EMB).
Internal Revenue Commissioner Charlito Martin R. Mendoza issued Revenue Memorandum Circular No. 096-2026 amending the VAT refund guidelines to cover VAT paid on local purchases and imports used for qualified zero-rated sales beginning November 28, 2024, up to the date their certification was issued.
The certification, however, must be issued within the prescribed transition period ending December 31, 2025, the BIR noted.
The clarification covers exporters that were already qualified for zero-rating but had yet to receive their DTI-EMB certifications when they incurred VAT on their purchases and imports.
‘Export-oriented enterprises received their VAT zero-rating certifications on different dates during the transition period,’ Mendoza said. ‘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.’
To qualify for a refund, EOEs must submit the necessary documents and show that the VAT they are claiming is directly related to their qualified zero-rated sales.
VAT that has already been reimbursed, credited, adjusted, recovered from suppliers or otherwise utilized may not be the subject of a VAT refund claim, the BIR said.
EOEs that met the 70-percent export threshold in the preceding taxable year but failed to secure the required DTI-EMB certification are likewise not entitled to a VAT refund for the immediately succeeding year, the bureau added.
Any unused input VAT may instead be carried forward to succeeding taxable quarters and used against future VAT liabilities, subject to existing tax rules.
‘Our objective is to ensure fair and consistent tax treatment for qualified export-oriented enterprises during the transition to the new zero-rating certification system,’ Mendoza said.
‘If they complied with the requirements and their certification was issued within the prescribed period, the VAT they properly incurred while waiting may be refunded in accordance with the law,’ he added.
The DTI issued Administrative Order No. 25-03 last March 2025, setting the certification guidelines for EOEs under the Create More Act. The BIR followed with RMC No. 37-2025 last April 2025, which laid out the procedures for claiming VAT refunds.
Under the earlier guidelines, EOEs could seek refunds for VAT incurred on local purchases and imports starting November 28, 2024, until the DTI-EMB began processing their zero-rating certifications.
However, the validity dates of the certifications varied during the transition period, ranging from May 14 to December 26, 2025, according to the BIR.