REVENUE REGULATIONS NO. 1-2017 issued on January 18, 2017 prescribes the regulations governing applications for Value-Added Tax (VAT) credit/refund filed under Section 112 of the Tax Code, as amended, prior to the effectivity of Revenue Memorandum Circular (RMC) No. 54-2014. VAT claims filed and pending prior to the effectivity of RMC No. 54-2014 shall be processed and approved in accordance with the following rules: a. The claimant-taxpayer, under Section 112 (A) of the Tax Code, as amended, has two (2) years, after the close of the taxable quarter when the sales were made, to apply for the issuance of a Tax Credit Certificate or refund of creditable input tax due or paid attributable to such sales. Thus, before the administrative claim is barred by prescription, the taxpayer must have submitted his/her complete documents in support of the application filed. b. In all cases, whatever documents a taxpayer intends to file to support his/her claim must be completed within the two-year period under Section 112 (A) of the Tax Code, as amended, and the Commissioner, or his duly authorized representative, should have decided on the claim for tax credit or refund within 120 days from the date of submission of complete documents, or from the date of filing of the application, if the claimant-taxpayer did not submit additional documents. Hence, pending administrative claims prior to the effectivity of RMC No. 54- 2014 shall be processed by the concerned offices based on available documents submitted by the claimant-taxpayer within the aforesaid statutory two-year period. For this purpose, the result shall be communicated in writing by the concerned revenue official. The following claims filed and pending before the effectivity of RMC No. 54-2014 are not covered by these Regulations: a. Those claims filed beyond the two-year statutory prescriptive period; b. Those denied in writing by the approving authority; c. Those approved or granted fully or partially by the approving authority; and d. Those already appealed to and pending with the Court of Tax Appeal (CTA) unless there is proof of withdrawal of the case filed with the CTA.