Philippines Court of Tax Appeals Issues Decision Clarifying Unutilized Input VAT Refunds on Zero-Rated Sales

The Philippine Court of Tax Appeals March 2 issued a decision in CTA EB No. 2971, clarifying unutilized input VAT refunds on zero-rated sales. The taxpayer, a domestic corporation, sought a refund of unutilized and excess input VAT for services rendered to its nonresident affiliates, and the Commissioner of Internal Revenue (CIR) denied the claim. The Court of Tax Appeals, Special Third Division, partially granted the refund claim, and the CIR sought review. On appeal, the Court of Tax Appeals, en banc, found that: 1) the administrative claim was validly filed and duly received, and that the Bureau of Internal ...