Attention Registered Business Enterprises (RBEs) and Export Companies!
The Philippine Economic Zone Authority (PEZA) has issuedMemorandum Circular No. 2025-052, dated September 29, 2025, clarifying which local purchases of goods and services may qualify asVAT Zero-Ratedunder theCREATE MORE Act (Republic Act No. 12066).
Key Highlights
✓Direct Attribution Required
Only goods and servicesdirectly attributableorreasonably necessaryto your registered project or activity may qualify for VAT zero-rating.
✓PEZA’s Authority Confirmed
PEZA, not the Bureau of Internal Revenue (BIR), is theInvestment Promotion Agency (IPA)authorized to determine VAT zero-rating eligibility.
✓Automatically Qualifying Purchases
Expenses listed in the “positive list” are deemed directly attributable. These include:rent, utilities, accounting, legal, janitorial, security, IT, HR, consultancy, logistics, and other similar services.
For Purchases Not on the Positive List
RBEs must first securePEZA confirmationby submitting the following requirements:
- Formal Letter Request(on company letterhead)
- Notarized Sworn Affidavit (Form ERD.2.F.008)signed by the CEO, President, or equivalent officer
- Send all documents via email toodg@peza.gov.phwith the subject line:
Request for VAT Confirmation – [Name of Registered Business Enterprise]
Why This Matters
This circular aligns PEZA’s procedures with theCREATE MORE Act’sstricter VAT framework, ensuring that only purchases genuinely tied to your registered operations enjoy VAT zero-rating.
Non-compliance may result inVAT disallowances, deficiency assessments, or penaltiesduring BIR post-audit.
Compliance Tip
Before claiming VAT Zero-Rating:
- SecurePEZA confirmationfor non-listed purchases.
- Keep yourSworn Affidavitand related proofs ready for audit.
This helps preserve your tax incentives and protects your company from potential disputes.
Legal Basis
PEZA Memorandum Circular No. 2025-052
Dated September 29, 2025
Issued by:Dir. Gen. Tereso O. Panga
Subject:Clarification on VAT Zero-Rating for Goods and Services Directly Attributable to Registered Activities under the CREATE MORE Act (RA 12066)
Tax Advisory
If your company needs assistance with:
- Drafting theSworn AffidavitorLetter of Request, or
- Evaluating which expenses may qualify forVAT Zero-Rating,
Bong Corpuz & Co. CPAs can help ensure your filings are compliant, well-documented, and aligned with both PEZA and BIR standards.
Talk to us today, let’s keep your compliance seamless and your incentives secure.
