REVENUE MEMORANDUM CIRCULAR (RMC) NO. 96-2026
This Circular provides clarification on the VAT refund qualification of Export-Oriented Enterprises (EOEs) during the transitory period for securing the VAT zero-rating certificate from the Department of Trade and Industry – Export Marketing Bureau (DTI- EMB).
| Particulars | Clarification |
| Who may claim? | EOEs that obtained a VAT Zero-Rating Certificate from DTI-EMB during the transitory period. |
| Refundable VAT | Passed-on VAT on local purchases and importations directly attributable to zero-rated sales. |
| Covered Period | From November 28, 2024 (effectivity of CREATE MORE) until the date the VAT Zero-Rating Certificate was issued. |
| Condition | The VAT Zero-Rating Certificate must have been issued within the transitory period. |
| Transitory Period | November 28, 2024 to December 31, 2025. |
| Documentary Requirements | The applicable checklist (RMC No. 37-2025) ii on the taxable period covered by the VAT refund claim: Annex A.1.1 for taxable periods prior to April 1, 2025; and Annex A.1.2 for taxable periods April 1, 2025, onwards. |
EOEs that have attained the 70% export threshold from the preceding taxable year but failed to secure certification from EMB (including during the transitory period) shall not be 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.
Moreover, only input VAT allowable under Section 112 of the Tax Code and directly attributable to qualified zero-rated sales shall be refundable, subject to compliance with all the documentary, substantiation, attribution, and verification requirements under existing laws, rules and regulations.
Furthermore, no refund shall be allowed to the extent that the VAT has already been reimbursed, credited, adjusted, recovered from suppliers, or otherwise utilized under the existing tax laws and regulations.