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

The Philippine Court of Tax Appeals Jan. 23 issued a decision in CTA Case No. 10626, clarifying unutilized input VAT refunds on zero-rated sales. The taxpayer, a corporation, sought a refund of unutilized input VAT related to export sales it argued were zero-rated. The Commissioner of Internal Revenue denied the claim on grounds including failure to substantiate the administrative claim, and that the taxpayer’s invoices weren’t covered by the approved Permit to Use Computerized Accounting System (PTUCAS). On appeal, the Court of Tax Appeals, Special Third Division, found that: 1) the invoices utilized were the taxpayer’s commercial invoices generated through ...