RR 8-2025: Stricter Framework for Requests for Reconsideration of Denied Refund Claims

On Feb. 27, 2025, the Bureau of Internal Revenue issued Revenue Regulations (RR) 8-2025, to streamline the procedure for handling requests for reconsideration of fully or partially denied claims for refund of creditable input taxes under Section 112(A) and (B) of the Tax Code; and excise tax paid on petroleum products under Section 135-A of the Tax Code.

- MARIA EVITA IGOT

This regulation aims to establish consistency and efficiency, but it does so by placing a far greater burden on taxpayers to comply with strict procedural rules.

In prior years, taxpayers often benefitted from informal leniency, submitting additional documents post-filing or clarifying factual matters directly with the BIR officer handling the claim. Now, the new process has removed any opportunity to correct or clarify factual concerns administratively.

Effective April 1, 2025, the regulation marks a sharp departure from past practices and imposes a more rigid structure for taxpayers seeking to reverse a denial of a refund claim from the BIR.

Under the new regulations, a request for reconsideration is defined as a plea for re-evaluation of a pure question of law on a given set of facts or circumstances based on previously submitted documents and arguments without need for introduction of new or additional documents.

Meanwhile, a question of law arises when there is doubt as to what the law is on a certain state of facts. It must not involve an examination of the probative value of the evidence presented by the applicant.

Based on RR 8-2025, the BIR will not revisit questions of fact, review additional submissions or entertain any new supporting documents. Hence, a request for reconsideration is simply a request to re-evaluate a denial based solely on legal grounds, using only the documentation that was originally submitted.