BIR clarifies tax refund filing offices and processing timelines

By Francis Allan L. Angelo

The Bureau of Internal Revenue has revised tax credit and refund procedures to clarify where taxpayers should file claims and which offices must process, review, and approve them.

For taxpayers seeking to recover excess withholding taxes or amounts wrongly collected, the changes are intended to reduce uncertainty over filing and follow-up. Clear processing periods also give claimants a basis for tracking applications involving money that could otherwise support household or business needs.

The BIR said three complementary issuances published Sept. 29, 2026 — Revenue Memorandum Circular Nos. 102-2026 and 103-2026 and Revenue Memorandum Order No. 25-2026 — amend existing tax credit and refund procedures.

They cover excess or unutilized creditable withholding taxes on income, taxes erroneously or illegally received or collected, and penalties imposed without authority.

“Taxpayers claiming a refund should not have to figure out which BIR office will accept their application, who is responsible for acting on it, or how long their claims will take to be processed. These amendments establish definite timelines and clear responsibilities within the Bureau to ensure that refund claims for unutilized creditable withholding taxes and erroneously/illegally collected taxes or penalties are handled consistently and in accordance with the law,” BIR Commissioner Charlito Martin R. Mendoza said in a press statement.

RMC No. 102-2026 updates the filing and documentary requirements for claims involving excess or unutilized creditable withholding taxes (CWT) on income.

For regular refund applications, the 180-day processing period begins when the taxpayer submits the application and complete supporting documents, according to the BIR release.

Claims involving dissolution or cessation of business fall under a special two-year processing period provided by Section 76(C) of the Tax Code, as amended.

The distinction makes the completeness of a regular application important to determining when the BIR’s processing period starts.

The circular amends RMC No. 75-2024, as previously amended by RMC No. 14-2025, according to the BIR’s official issuance index.

RMC No. 103-2026 clarifies filing offices for claims involving taxes erroneously or illegally received or collected, or penalties imposed without authority.

Claims involving capital gains tax (CGT) on the sale of real property classified as a capital asset, together with the related documentary stamp tax (DST), must be filed with the Revenue District Office (RDO) covering the property’s location.

Other covered claims must be filed with the RDO, Large Taxpayers Audit Division (LTAD), or Large Taxpayers Division (LTD) that has jurisdiction over the taxpayer-claimant.

This circular amends RMC No. 74-2024. The BIR’s index identifies both updated circulars as excluding claims under the authority and jurisdiction of its Legal Group.

RMO No. 25-2026 complements the filing rules by assigning processing, review, and approval responsibilities for the covered claims, regardless of the amount sought.

Designated revenue officers will receive applications and check whether the required documents are complete.

For claims processed by RDOs, the Assessment Division will conduct the review, while the regional director will approve the claims.

For claims processed by the LTAD or LTD, the concerned head revenue executive assistant of the Large Taxpayers Service (LTS) will conduct the review. The LTS assistant commissioner will approve them.

The BIR said clearer filing procedures and defined responsibilities are intended to improve refund administration and ensure consistent handling of taxpayer claims.