Philippines Supreme Court Clarifies Unutilized Input VAT Refunds Attributable to Zero-Rated Sales of PEZA-Registered Entities

The Philippine Supreme Court Aug. 4 posted online a decision in G.R. Nos. 251333-34, clarifying unutilized input VAT refunds attributable to the zero-rated sales of entities registered with the Philippine Economic Zone Authority (PEZA). The taxpayer, a registered export enterprise with the PEZA, filed an administrative claim requesting a refund of unutilized input VAT attributable to its zero-rated sales. The Court of Tax Appeals (CTA), en banc, denied the claim, contending that the taxpayer was a VAT-exempt entity and wasn’t the proper party to seek a refund. Upon review, the Supreme Court reversed the CTA’s decision, finding that: 1) the ...