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

Jan. 27, 2026, 5:00 AM UTC

The Philippine Court of Tax Appeals Jan. 16 issued a decision in CTA EB No. 2951, clarifying unutilized input VAT refunds on zero-rated sales. The taxpayer, a corporation engaged in export sales of goods, sought a refund of unutilized input VAT. The Commissioner of Internal Revenue (CIR) denied the request, contending that the taxpayer didn’t prove that its recipient of services wasn’t doing business in the Philippines. The Court of Tax Appeals, First Division, partially granted the claim, and the CIR sought review. On appeal, the Court of Tax Appeals, en banc, found that: 1) the taxpayer wasn’t required to ...

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