RR 6-2025

Revenue Regulations No. 6-2025 (February 27, 2025) implements Section 135 and the new Section 135-A of the National Internal Revenue Code of 1997, as amended by RA No. 12066 (CREATE MORE Act), on refund of excise tax on petroleum products. It restates that petroleum products sold to (a) international carriers of Philippine or foreign registry for their use or consumption outside the Philippines, (b) exempt entities or agencies covered by tax treaties and other international agreements subject to a reciprocity condition, and (c) entities exempt by law from direct and indirect taxes, are exempt from excise tax. It prescribes the refund process for suppliers: a written claim with the CIR within two (2) years from payment of the excise tax; a return showing an overpayment is treated as a written claim; a ninety (90)-day decision period counted from submission of complete documents; a written denial stating the legal and factual basis; a fifteen (15)-day request for reconsideration limited to questions of law, decided within fifteen (15) days; and appeal to the Court of Tax Appeals within thirty (30) days in defined situations. Refunds are paid by warrant without COA countersignature but remain subject to COA post-audit, with the taxpayer liable for any disallowance; BIR personnel who deliberately delay processing are punishable under Section 269(J). The regulations cover refund claims filed starting April 1, 2025 onwards.