How to File a VAT Refund: Our Step-by-Step Experience

We filed in March 2025 our VAT Refund for the 1st Quarter of Taxable Year 2023, while the 2nd & 3rd Quarter of Taxable Year 2023 in May 2025 and lastly we filed the 4th Quarter of Taxable Year 2023 in September 2025. After filing our VAT refund claim for taxable year 2023 in 2025 and another claim for taxable year 2024 in March 2026, one thing became clear: filing an application for VAT refund claim is not a project you start a week before the deadline.

VAT Refund is straightforward, compliant Invoices with supporting documents allowed, non-compliant disallowed. So the real work lies in gathering documents, reconciling records, preparing schedules, and ensuring compliance with the latest BIR requirements.

Now we are preparing our VAT refund claim for taxable year 2025 under RMC No. 37-2025, I’d like to share the actual experience, work we did for a service company with VAT zero-rated sales to PEZA-registered clients.

Step 1: Confirm That Your Sales Qualify for VAT Zero-Rating

In our case, at the beginning we already know which one is qualified becuse it’s stated in the Project Contract if it’s zero-rated or not.

BUt for filing purposes, there’s no harm to review the following:

• Project Contract
• PEZA registrations of clients
• Invoices claimed for the refund must be compliant and properly filled up
• Applicable BIR regulations

Remember, not all sales qualify for VAT refund purposes.

A VAT refund claim starts with establishing that the underlying transactions are legally entitled to VAT zero-rating.

Step 2: Identify the Claim Period

This is important since there is a deadline in VAT Refund Filing which is two (2) years from the close of the taxable year.

In our VAT Refund for the taxable year 2023, we filed the 1st Quarter of Taxable year 2023 in March 2025 since it will expre after March.

Step 3: Gather All Supporting Documents

This is often the most time-consuming stage.

For our claims, we gathered:

• BIR Form 2550Q (Quarterly VAT Returns)
• Service Invoices
• Contracts and Service Agreements
• Books of Accounts
• Financial Statements
• Summary Lists of Sales and Purchases
• Proof of payment of purchases
• Supplier invoices supporting input VAT claims

Even if not filing for VAT Refund these documents should be properly filed and documented in Accounting Department. So, it is assumed to be reaadily available, we just have to review.

Step 4: Reconcile VAT Returns and Accounting Records

In our case, we compare

• Sales per VAT returns (2550Q) versus sales per book
• Input VAT per books versus input VAT claimed
• Purchases versus supporting invoices

This step helps identify discrepancies before the claim is filed.

In our experience, many issues can be resolved at this stage before they become questions during verification.

Step 5: Prepare the Schedule of Zero-Rated Sale of Services

(Annex “A1.5.2” for claims covering the effectivity of EOPT on April 27, 2024)

For service companies, this is one of the most important schedules.

The schedule includes:

• Service Invoice Number
• Invoice Date
• Customer Name
• Country
• Sales/Billing Amount
• Conversion Rate, when applicable
• Peso Equivalent
• Date of Remittance
• Bank Information

Every amount in the schedule should agree with the corresponding service invoice and accounting records.

Step 6: Prepare the Other Required Schedules

Depending on the transactions during the claim period, prepare the following schedules:

Annex “A.1.7” Schedule of Taxable Sales

This serves as a reconciliation of VATable transactions reported in VAT returns.

Annex “A.1.6” Schedule of Exempt Sales

This discloses exempt transactions during the period.

Annex “A.1.8” Schedule of Local Purchases with Input Tax

Fill up this schedule of all local purchases be it pertaining to zero-rated sales or not. Just extend the claimable amount to another column.

For each supplier, we disclose:

• Supplier Name
• TIN
• Invoice Number
• Invoice Date
• Amount of Purchase
• Input VAT Amount

In this schedule, invoices must be reviewed extensively for it’s compliance. Compliant invoice allowed, non-compliant disallowed.

Annex “A.1.8_BT” Schedule of Big-Ticket Purchases

If applicable, major purchases and capital expenditures must be separately disclosed.

Note: Make sure the data in these schedules matches the data in 2550Q.

Step 7: Accomplish BIR Form No. 1914

After completing all schedules and reconciliations, prepare BIR Form No. 1914 (Application for Tax Credits/Refunds).

The form requires:

• Taxpayer Information
• Claim Period
• Claim Amount
• Type of Claim
• Legal Basis of the Claim

By this stage, most of the work has already been completed.

The key is ensuring that the claim amount agrees exactly with the supporting schedules.

Step 8: Prepare the Required Taxpayer’s Attestation

For claims filed under RMC No. 37-2025, a notarized Taxpayer’s Attestation (Annex A.1.3.2) must be submitted.

This attestation certifies that:

• The documents submitted are complete;
• The documents submitted are authentic;
• The records support the claim;
• The books of accounts are available for verification.

Step 9: Review the Checklist Under Annex A.1.2

One lesson we learned from previous filings is that incomplete submissions can delay processing.

Before filing, we review the documentary checklist under Annex A.1.2 of RMC No. 37-2025 and verify that all required documents are included.

We literally tick off every document one by one before submission.

Step 10: Conduct a Final Internal Review

Before filing, we verify:

✓ Form 1914 agrees with all schedules

✓ Schedules agree with VAT returns

✓ VAT returns agree with accounting records

✓ Input VAT claimed is properly supported

✓ Documentary requirements are complete

This step has helped us identify issues before submission and avoid unnecessary delays.

Step 11: Submit the VAT Refund Application

Once all documents are complete, submit the application package to the appropriate BIR processing office.

One interesting observation from our experience was that our 2023 claim was filed with the VAT Audit Section (VATAS) in BIR Region No. 7 at The Podium, Ortigas Center, while our 2024 claim filed in March 2026 was already submitted through Revenue District Office No. 043 following organizational changes within the BIR.

This highlights the importance of checking the latest filing procedures before submission.

Step 12: Cooperate During Verification

The filing of the application is not the end of the process.

During verification, the BIR may request:

• Additional schedules
• Clarifications
• Books of Accounts
• Supporting invoices
• Reconciliation reports

Prompt responses and organized records can significantly help the verification process.

Final Thoughts

Based on our experience with VAT refund claims for taxable years 2023 and 2024, the most important advice I can give is to start early.

Preparing BIR Form No. 1914 takes only a few minutes.

Preparing the schedules, reconciling records, validating invoices, and organizing documentary requirements can take weeks or even months.

The stronger your documentation, the stronger your VAT refund claim.