The Supreme Court on Wednesday clarified the prescriptive periods for filing value-added tax (VAT) refund claims with the Commissioner of Internal Revenue (CIR).
In CIR v. Dohle Shipmanagement Philippines Corporation, the SC’s Third Division ruled that for VAT refund claims filed before June 11, 2014, the 120-day period for the CIR to resolve the claim begins when the taxpayer determines that its submission of documents is complete.
The High Court emphasized the 120-day period is intended to benefit taxpayers by ensuring the CIR acts on its claim.
Therefore, the taxpayer decides when all documents are complete to start the 120-day period.
The sooner the taxpayer processes the refund, the sooner it can be used to grow the taxpayer’s business, according to the SC.
It added that the 30-day period to submit additional documents under RMC 49-2003 applies when the CIR determines that the taxpayer’s submission is incomplete and not when the taxpayer voluntarily submits additional documents.
