Philippines Court of Tax Appeals Issues Decision Clarifying VAT Refund Assessment for Zero-Rated Transactions

The Philippine Court of Tax Appeals March 25 issued a decision in CTA Case No. EB 2788, clarifying an input VAT refund assessment on zero-rated transactions. The taxpayer, a company acting as a representative or broker of ships for owners and operators, sought a refund of unutilized input VAT, attributable to its alleged zero-rated transactions, claiming that the services rendered to its nonresident clients were performed in the Philippines. The Bureau of Internal Revenue (BIR) denied the refund, citing violations of invoicing requirements and insufficiency of documentation for zero-rated sales. On review, the Court of Appeals, Third Division, denied taxpayer’s ...