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

March 9, 2026, 5:00 AM UTC

The Philippine Court of Tax Appeals Feb. 20 issued a decision in CTA EB No. 2947, clarifying unutilized input VAT refunds on zero-rated sales. The taxpayer, Schaeffler Philippines Inc., sought a refund of unutilized input VAT for Q1 2018. The Commissioner of Internal Revenue (CIR) partially denied the claim, asserting noncompliance with invoicing rules and the taxpayer’s failure to present original Board of Investments (BOI) documents proving zero-rating entitlement. The Court of Tax Appeals, First Division, denied the claim, and the taxpayer appealed. On appeal, the Court of Tax Appeals, en banc, found that: 1) the taxpayer’s photocopied BOI documents ...

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