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

The Philippine Court of Tax Appeals April 7 issued a decision in CTA Case No. 11012, clarifying unutilized input VAT refunds on zero-rated sales. The taxpayer, a VAT-registered power generation company, sought a refund of unutilized input VAT attributable to its alleged zero-rated sales. The Commissioner of Internal Revenue (CIR) denied the claim for the lack of a legal basis and failure to meet substantiation and invoicing requirements. On appeal, the Court of Tax Appeals, Special Second Division, found that: 1) the administrative and judicial claims were timely filed; 2) only sales of power generated from renewable sources qualified as ...