BIR issued Revenue Regulations (RR) No. 8-2025 to update the procedures in the resolution of requests for reconsideration on the full or partial denial of claims for refund of the following taxes starting April 1, 2025:

  1. Creditable input taxes under Section 112(A) and (B) of the Tax Code; and
  2. Excise tax paid on petroleum products under Section 135-A of the Tax Code.

RR No. 8-2025 specifies the following rules:

  1. All requests for reconsideration on full or partial denial of a claim for refund should be limited to questions of law. Any issue/s relating to factual determination or appreciation should have been threshed out during the initial processing of the claim for refund and contained in the notice of full or partial denial. Consequently, any factual issue raised in the request for reconsideration shall no longer be entertained.
  1. Only the documents previously attached to the taxpayer-claimant’s application for tax refund relevant to the issues raised may be submitted with the request for reconsideration. Introduction of new evidence/document, as well as questions of law already addressed in the Notice of Full or Partial Denial, shall not be allowed during the request for reconsideration.
  1. The processing time to act on the taxpayer-claimant’s request for reconsideration shall be within fifteen (15) days from the date of actual receipt of the request for reconsideration by the concerned Processing Office, as provided for under Section 5 hereof. Consequently, failure to file with the Processing Office shall render the request for reconsideration invalid and shall not toll the running of the fifteen (15)-day period to file the request for reconsideration. Hence, the partial or full denial of the refund shall become final and executory after the lapse of such period.
  1. No supplemental or amended appeal, or any other pleading of similar import, shall be allowed notwithstanding that the same is filed within the fifteen (15)-day prescribed period to file a request for reconsideration. Further, no second request for reconsideration shall be allowed. The filing of a second request for reconsideration shall not toll the running of the prescriptive period to file an appeal before the Court of Tax Appeals (CTA).
  1. Failure to comply with any of these requirements regarding the period, form, or manner of filing shall constitute sufficient ground for the outright denial of the same.
  1. The decision on the request for reconsideration shall be issued within the fifteen (15)-day processing period from actual receipt of the request by the Processing Office.
  1. Upon timely filing of the request for reconsideration, the processing of the refund claim subject of the request for reconsideration, if granted, shall be made within twenty (20) days from the date the decision is issued.
  1. Notwithstanding the filing of the request for reconsideration, the taxpayer-claimant may withdraw the same at any time before it is finally resolved, in which case, the full or partial denial shall stand as though no such request for reconsideration has been filed. The full or partial denial shall then be deemed final upon the lapse of the fifteen (15)-day period from the date of receipt by the taxpayer-claimant of the notice of full or partial denial of the claim for refund.

In case of full or partial denial of the request for reconsideration, or in case of inaction thereon by the CIR or his duly authorized representative, the taxpayer-claimant may appeal the full or partial denial of the request for reconsideration or the full or partial denial of the claim for refund in case of inaction on the request for reconsideration, to the CTA within thirty (30) days from receipt of the decision or from the lapse of the fifteen (15)-day period to decide thereon