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

December 12, 2025, 5:00 AM UTC

The Philippine Court of Tax Appeals Dec. 5 issued a decision in CTA Case No. 10936, clarifying unutilized 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 for calendar year 2020. The Commissioner of Internal Revenue (CIR) partially denied the request, contending that the taxpayer failed to fully substantiate its administrative claim for a refund. On appeal, the Court of Tax Appeals, Third Division, partially granted the taxpayer’s appeal, finding that the taxpayer: 1) sufficiently proved that the zero-rated sales were made to Philippine Economic Zone ...

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