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

May 12, 2025, 5:00 AM UTC

The Philippine Court of Tax Appeals May 6 issued a decision in CTA Case No. 10462, clarifying refunds of unutilized input VAT on zero-rated sales. The taxpayer, a nonresident company, sought a refund of unutilized input VAT on its zero-rated sales for Q3 and Q4 of 2018. The Commissioner of Internal Revenue (CIR) denied the taxpayer’s refund request, claiming that the taxpayer failed to substantiate its refund claim at the administrative level. The taxpayer appealed, arguing that it was entitled to a refund of the duly substantiated unutilized and excess creditable input VAT attributable to its export zero-rated sales. In ...

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