iii. Proper Party to File Claim for Refund or Tax Credit

Proper Party to File Claim for Refund or Tax Credit

Tax refunds are in the nature of tax exemptions and are construed strictissimi juris against the claimant¹. Consequently, any party claiming a refund bears the burden of justifying the entitlement by the clearest grant of organic or statutory law¹.

In CIR v. Interpublic Group of Companies, Inc., G.R. No. 207039, 14 August 2019, the claimant was not deprived of its right to claim a tax refund after it successfully discharged the burden of proof required by law¹. Moreover, the factual determinations of the Court of Tax Appeals regarding a claimant's compliance and discharge of this burden are binding upon the Supreme Court, unless they are shown not to be supported by substantial evidence¹.