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

Nov. 24, 2025, 5:00 AM UTC

The Philippine Court of Tax Appeals Nov. 12 issued a decision in CTA Case No. 10938, clarifying refunds of unutilized input VAT regarding zero-rated sales. The taxpayer, a domestic corporation, sought a refund of alleged unutilized input VAT attributable to its zero-rated sales. The taxpayer argued that the services it rendered to a Singaporean private company were zero-rated and so the input VAT attributable to such services could be claimed through a tax refund. The Commissioner of Internal Revenue (CIR) disagreed, contending that the taxpayer failed to comply with applicable invoicing and accounting requirements for VAT-registered persons. On appeal, the ...

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