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

The Philippine Court of Tax Appeals Oct. 29 issued a decision in CTA EB No. 2921, clarifying input VAT refunds on zero-rated sales. The taxpayer, a foreign company’s regional Philippine headquarters, sought a refund of unutilized input VAT on services it provided. The Bureau of Internal Revenue (BIR) partially denied the refund for failure to submit an incorporation certificate from a client’s foreign country. The Court of Tax Appeals, Special Third Division, granted the taxpayer a partial refund, and the parties appealed. Upon review, the Court of Appeals, en banc, held that: 1) a certification of non-registration proved that the ...