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Philippine Bar review · Question

Practice question: Tax Refund and Tax Credit

Multiple Choice Hard

Practice question

In a covered 2026 refund-denial reconsideration, a taxpayer submits invoices never included in the original application and seeks factual reappreciation, without an allowable legal issue under RR 8-2025. It says reconsideration automatically reopens evidence. Which is correct under the regulation?
  1. Every new invoice must be accepted without limitation
  2. Every request restarts the original claim period
  3. The taxpayer may always obtain unlimited factual rehearings
  4. The regulation limits reconsideration to legal issues and previously submitted pertinent documents, excluding the stated new-evidence approach
  5. The regulation abolishes all CTA review

Legal references

  • BIR RR 8-2025, VAT refund denial reconsideration requirements: https://bir-cdn.bir.gov.ph/BIR/pdf/RR%208-2025.pdf
  • RA 12066, Sections 6-9, amended NIRC Sections 106, 108, 109 and 112(C): https://lawphil.net/statutes/repacts/ra2024/ra_12066_2024.html

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