PEZA Memorandum Circular No. 2025-020: VAT Certification Nos. 2025-0299 to 2085 and 2025 VAT Updated Issue No. 0002-0011

The Republic Act No. 12066 or the Corporate Recovery and Tax Incentives for Enterprises to Maximize Opportunities for Reinvigorating the Economy Act (“CREATE More Act”) provides that the Value Added Tax (“VAT”) zero-rating on local purchases shall apply only to goods and services directly attributable to the registered project or activity of a Registered Export Enterprise or a High-Value Domestic Market Enterprise, including incidental expenses thereto. According to its Implementing Rules and Regulations, “directly attributable” shall refer to goods and services that are incidental to and reasonably necessary for the registered project or activity of the Registered Business Enterprise, including janitorial, security, financial, consultancy services, marketing and promotion, and services rendered for administrative operations such as human resources, legal, and accounting. 
In view of the foregoing, the Philippine Economic Zone Authority (“PEZA”) issued Memorandum Circular No. 2025-020 informing all registered export enterprises of the need to amend the second paragraph of the VAT Zero-Rating Certifications issued by PEZA prior to the effectivity of the CREATE More Act, to read as follows:

From

To

This is to certify that (enterprise acronym) is a qualified export enterprise for the purpose of VAT zero-rating of its transactions with its local suppliers of goods and services directly and exclusively used in the registered project or activity, in accordance with Section 295(D) of the Republic Act (RA) No. 11534, otherwise known as the “Corporate Recovery and Tax Incentives for Enterprise Act” or “CREATE”, and Rule 2 Section 5 of the Rules and Regulations to Implement Title XIII of the National Internal Revenue Code of 1997 (NIRC), as amended, and applicable Revenue Regulations of the BIR.

This is to further certify (enterprise acronym) is a qualified export enterprise for the purpose of VAT zero-rating of its transactions with its local suppliers of goods and services directly attributable to the registered project or activity, including expenses incidental thereto, including janitorial, security, financial consultancy services, marketing and promotion, and services for administrative purposes such as human resources, legal, and accounting, in accordance with Section 295 (D) of the National Internal Revenue Code of 1997, as amended further, by Republic Act (RA) No. 12066 or the “Corporate Recovery and Tax Incentives for Enterprises to Maximize Opportunities for Reinvigorating the Economy” (CREATE More Act), and applicable Revenue Regulations of the BIR

All registered export enterprises with VAT Zero-rating Certifications valid for the year 2025 issued by PEZA prior to the effectivity of the CREATE MORE Act on 28 November 2024, are required to file an application for an Updated Issue of the VAT Zero-rating Certification. No processing fees shall be imposed for the application.