REVENUE MEMORANDUM CIRCULAR NO. 51-2007 issued on July 31, 2007 circularizes the revisions on the New Paradigm in meeting the collection target as embodied in the memorandum issued by the Officer-In-Charge – Commissioner of Internal Revenue (OIC-CIR) dated July 27, 2007, to wit:

1. Except for cases falling under the jurisdiction of the Large Taxpayer Service (LTS), claims for cash/Tax Credit Certificates (TCCs) must observe the following processes:
   1. For cases One Million (P 1M) and below, the following procedures shall be followed:
      • Claims of P 1M and below are to be processed and reviewed by the Revenue District Office (RDO) having jurisdiction over the claimant with the Regional Director (RD) as the approving official.
      • If in the process, legal questions or questions of law arise, the Revenue Officer (RO) assigned shall request for a legal opinion on the issues raised. The Legal Division shall resolve the legal question and issue an opinion on the matter. The ruling issued by the Legal Division shall form part of the records of the case.
   2. For claims/cases of more than P 1M but not exceeding Ten Million (P 10M), the following procedures shall be followed:
      • Such claims shall be filed and processed in the RDO having jurisdiction over the claimant. Review shall be done in the Revenue Region (RR) and shall be forwarded to the Assessment Service (AS). The certificates shall be signed by the Assistant Commissioner-Assessment Service (ACIR-AS) as the final approving official.
      • If legal questions arise, the RO shall request a legal opinion. The Legal Service (LS) shall issue an opinion to be attached to the docket and form part of the case record. The docket shall remain with the RO.
      • In case of conflict between the LS ruling and AS decision, the matter shall be resolved by the concerned Deputy Commissioner of Internal Revenue (DCIR) or Commissioner of Internal Revenue (CIR).
   3. For claims above P 10M:
      • All such claims must be recommended and signed by the ACIR-AS and forwarded to the Office of the DCIR for Operations Group (ODCIR-OG) for final approval.
      • If legal issues arise, the RO shall request a legal opinion. The LS shall issue a ruling, which shall be included in the case docket. After issuance, the ACIR-AS shall forward the docket to the ODCIR-OG.
      • Any conflict between the LS ruling and AS decision shall be resolved by the concerned DCIR or CIR.
2. For claims for cash refunds/TCCs filed in the LTS (LTAID I, LTAID II & LTDO), the following rules shall be observed:
   1. All claims amounting to P 10M and below shall be reviewed and approved by the ACIR-LTS or the respective Head Revenue Executive Assistant (HREA) in the absence of the former.
   2. If the amounts involved exceed P 10M, the final approving authority shall be the CIR.
   3. If legal questions arise, the RO shall request a legal opinion. The LS shall issue an opinion to be attached to the docket. After issuance, the docket shall be forwarded to the CIR for final approval.
3. For Value-Added Tax (VAT) claims filed in the One-Stop-Shop (OSS) Center of the Department of Finance (DOF), the following procedures are to be observed:
   1. Claims amounting to P 10M and below filed in the OSS-DOF shall be reviewed and processed by the AS. The ACIR-AS shall be the approving official.
   2. Claims exceeding P 10M shall be reviewed and recommended by the ACIR-AS to the DCIR-OG for final approval.
   3. Dockets transmitted back to OSS-DOF for compliance need not go through DCIR-OG again. The ACIR-AS shall return them directly to the originating office to avoid delays.
4. For cases decided by courts which require the issuance of TCCs, the Appellate Division shall prepare the TCCs to be signed by the ACIR-LS as the final approving official.