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

The Philippine Court of Tax Appeals March 23 issued a decision in CTA Case No. 10915, clarifying unutilized input VAT refunds on zero-rated sales. The taxpayer, a Philippines-based group company of Nippon Express, sought a refund of unutilized input VAT attributable to its zero-rated sales. The Commissioner of Internal Revenue denied the claim for insufficient substantiation. On appeal, the Court of Tax Appeals, Special Third Division, found that: 1) sales to entities with valid ecozone registrations were zero-rated, but not sales to entities registered with the Board of Investment (BOI), due to lack of certification; 2) sales to the Asian ...