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. 21 issued a decision in CTA Case No. 10505, clarifying unutilized input VAT refunds on zero-rated sales. The taxpayer, a corporation, sought a refund of excess and unutilized input VAT for taxable year 2018, arguing that it complied with the specified invoicing requirements and that the 12 percent output VAT deduction against the unutilized input VAT wasn’t proper. The Commissioner of Internal Revenue (CIR) denied the request, contending that the taxpayer failed to substantiate its administrative refund claim and prove its entitlement to the specified VAT refund amount. On appeal, the Court of ...

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