Title
Amendment on Excise Tax Exemptions and Product Replenishment
Law
Bir Revenue Regulations No. 3 - 2008
Decision Date
Jan 22, 2008
BIR Revenue Regulations No. 3-2008 amends existing tax provisions to impose excise tax on the removal of articles intended for export or delivery to tax-exempt entities, while establishing guidelines for tax credit claims and product replenishment to prevent abuse and ensure revenue stability.
A

Scope of Regulations

  • Amend provisions granting outright excise tax exemptions on removal of excisable articles for export, sale/delivery to international carriers, or tax-exempt entities/agencies.
  • Prescribe mechanisms for claims for product replenishment.
  • Promulgated under Sections 244 and 245 of the NIRC of 1997, as amended.

Imposition of Excise Tax on Removal

  • Manufacturers must pay excise tax due on removal from production site intended for export, international carriers, or tax-exempt entities.
  • If articles sold domestically, excise tax rate same as domestic sales.
  • If no domestic equivalent, excise tax based on declared value.
  • BIR-bonded storage facility permits revoked; excise tax due on such inventories.
  • Separate regulations apply for bonded customs facilities and economic/freeport zones.

Discovery of Tax-Paid Articles in Domestic Market

  • Finding such articles domestically does not automatically amend export permits.
  • Penalties apply for violations.

Compliance with Printing Requirements

  • Strict compliance with labeling and packaging print rules required.
  • Non-compliance disqualifies entitlement to tax credit/refund or product replenishment.

Exemption Conditions for Certain Entities

  • Embassies, legates (e.g., Papal Nuncio), international organizations may remove articles without excise tax upon:
    • Securing prior written permit from LTAD II.
    • Submitting liquidation report within 30 days including specific documentary requirements.
  • Subsequent permits contingent on liquidation submission.

Claim for Product Replenishment

Conditions:

  • Manufacturer may opt for product replenishment instead of tax credit/refund after excise tax prepayment.
  • Articles for export or delivery to international carriers or tax-exempt agencies can be removed tax-free to replenish previously taxed exported articles, provided sufficient excise tax credit.
  • Differences in tax due must be settled or excess balance carried forward.
  • Changes in excise tax rates treated accordingly.
  • Claims filed per shipment with excise tax paid on removal; advance deposit payments not accepted.
  • Proper documentary submission within 90 days required; failure results in tax assessment.

Application Process:

  • File application for Product Replenishment Certificate (PRC) with Chief, LTFOD.
  • Required documents vary by transaction type (export, international carriers, freeport zones), including permits, invoices, delivery receipts, customs documents, proof of payment, and certifications.

Time and Processing:

  • Application filed within 90 days from shipment.
  • Denial or untimely filing does not bar filing tax credit/refund claims.
  • PRC issued within 10 days from complete filing.

Utilization and Validity:

  • PRC authorizes removal without excise payment, subject to no outstanding tax liabilities.
  • Valid for 5 years; one-time revalidation allowed.
  • PRC may be converted to Tax Credit Certificate (TCC) or refund.
  • Sale, transfer, or assignment of PRC prohibited.
  • Compliance with BIR withdrawal forms is mandatory.

Disallowance of Claims for Imported Articles

  • Excise tax claims do not cover imported components in excisable articles.
  • Separate claim process with BIR and Bureau of Customs for imported content.
  • Imported articles excluded from product replenishment.

Transitory Provisions

  • Manufacturers must submit notarized inventory of under-bond articles with proofs of excise tax payment within 5 days from effectivity.
  • Heads of Excise Tax Areas forward lists within 24 hours.
  • BIR validates and collects deficiencies.
  • Excise tax payments for under-bond inventory must indicate subject to replenishment/refund.

Penalties

  • Violations subject to penalties under Title X of NIRC.

Repealing Clause

  • All inconsistent regulations, rulings, or orders revoked or amended.

Effectivity

  • Regulations effective 15 days after publication in newspapers of general circulation.

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