90-day VAT Refunds under Revenue Memorandum Order No. 25-2019

On 15 May 2019, the Bureau of Internal Revenue released the procedures implementing the 90-day period under TRAIN to process and grant VAT refund claims.

Direct exporters must file their claims with the VAT Credit Audit Division (VCAD), while zero-rated claimants or those with cancelled VAT registration must file with the Revenue District Offices (RDOs) or the Large Taxpayers Audit Division (LTAD) exercising jurisdiction over the taxpayer.

Claims of taxpayers with outstanding delinquent tax liabilities shall not be accepted unless the liability pertains solely to VAT.

The revenue office shall issue a Tax Verification Notice which shall not be construed as an audit/investigation.

The total period to process, review and approve or disapprove the claim is 75 days from receipt of application. The result of the evaluation shall be communicated to the taxpayer in writing immediately after approval by the designated revenue official of the memorandum report.

The remaining 15 days is allotted for processing the payment for approved claims. The approving authorities are:


Approving Authority


Not more than Php50M

ACIR-Administrative Service

More than Php50M to Php150M

DCIR-Operations Group

More than Php150M


Large Taxpayers Service (LTS)

ACIR-LTS (but CIR signs the BOC endorsement, if any)


Regional Director

Any official, agent or BIR employee who fails to act on the application within the prescribed timeframes shall be fined up to Php100,000 and imprisoned from 10 to 15 years. The official shall also suffer perpetual disqualification to hold public office, to vote, and to participate in any public election.

The administrative processing of the claim may still continue beyond the 90-day period subject to penalties that may be incurred by the BIR official found grossly negligent in the performance of his/her duties.

Click hereto read the entire text of RMO No. 25-2019.

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