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

The Philippine Court of Tax Appeals Dec. 15, 2025, issued a decision in CTA Case No. 10972, clarifying unutilized input VAT refunds on zero-rated sales. The taxpayer, a corporation, sought a refund of excess and unutilized input VAT attributable to its zero-rated sales for taxable year 2020. The taxpayer argued that it complied with all requirements for a valid refund. The Commissioner of Internal Revenue (CIR) denied the request, contending that the taxpayer failed to fully substantiate its claim and used allegedly unauthorized invoices. On appeal, the Court of Tax Appeals, Third Division, partially granted the taxpayer’s appeal, finding that ...