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

December 9, 2025, 5:00 AM UTC

The Philippine Court of Tax Appeals Dec. 2 issued a decision in CTA EB Nos. 2915 and 2916, clarifying input VAT refunds on zero-rated sales. The taxpayer, a corporation, sought a refund of excess and unutilized input VAT attributable to zero-rated sales. The Court of Tax Appeals, Special Second Division, partially granted it. On appeal, the Court of Tax Appeals, en banc, found that: 1) the taxpayer proved, through articles of incorporation and a Securities and Exchange Commission certificate of non-registration, that its client was a nonresident foreign corporation not doing business in the country; 2) the input VAT no ...

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