Practice question
A properly filed 2026 VAT refund request is partially denied. The taxpayer timely obtains a decision denying its proper reconsideration request. It proposes filing repeated reconsideration requests to keep the matter pending instead of observing the CTA appeal window. What is the strongest response?
- Repeated requests indefinitely extend judicial deadlines
- The applicable judicial period is 30 days from receipt of the decision denying reconsideration; a second request does not toll it under RR 8-2025
- Partial denial can never be reviewed
- The initial ninety-day period restarts with every letter
- Only full denials require any deadline analysis
Legal references
- NIRC Section 112(C), as amended by RA 12066, Section 9: https://lawphil.net/statutes/repacts/ra2024/ra_12066_2024.html
- RR 8-2025 (claims filed on or after April 1, 2025): https://bir-cdn.bir.gov.ph/BIR/pdf/RR%208-2025.pdf
Answer this question in flashcards to review your response and continue practicing.