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

March 10, 2026, 5:00 AM UTC

The Philippine Court of Tax Appeals March 2 issued a decision in CTA EB No. 2864, clarifying unutilized input VAT refunds on zero-rated sales. The taxpayer, a domestic corporation, sought a refund of excess and unutilized input VAT attributable to zero-rated sales for Q3 and Q4 of 2017. The Commissioner of Internal Revenue (CIR) denied the taxpayer’s administrative claim for refund, contending that the taxpayer submitted incomplete supporting documents. The Court of Tax Appeals, Special First Division, partially granted the claim, and the CIR sought review. On appeal, the Court of Tax Appeals, en banc, found that: 1) the Court ...

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