Practice question
A taxpayer timely and properly seeks reconsideration of a 2026 VAT refund denial. The Commissioner does not act within the prescribed 15-day reconsideration period. What follows under the current statute?
- The request remains pending forever with no judicial remedy
- The claim becomes automatically exempt from all verification
- Only another administrative request is allowed
- A second reconsideration is mandatory
- The taxpayer may appeal to the CTA within 30 days after the 15-day decision period expires
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
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