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

The Philippine Court of Tax Appeals Nov. 4 issued a decision in CTA Case No. 11075, clarifying input VAT refunds on zero-rated sales. The taxpayer, a domestic corporation, sought a refund of unutilized input VAT on sales it made to a related Bermudan corporation to which it provided call center and customer support services. The Bureau of Internal Revenue (BIR) denied the refund, citing failure to substantiate the administrative claim. The taxpayer appealed, arguing that sales to a nonresident foreign corporation (NRFC) are zero-rated. On appeal, the Court of Tax Appeals, Second Division, held that: 1) official receipts lacked information ...