Philippine Court Upholds Denial of VAT Refund for Clinical Research Firm’s Zero-Rated Sales

The Philippine Court of Tax Appeals issued a decision on input VAT refunds for zero-rated sales.
A Philippine company involved in clinical research sought a refund for services provided to its UK-based affiliate.
The Bureau of Internal Revenue denied the refund request.
The taxpayer’s appeal to the Court of Tax Appeals, Special Second Division, was unsuccessful.
The full bench of the Court of Tax Appeals upheld the denial.
The court found the refund claim was filed incorrectly with a local office instead of the VAT Credit Audit Division.
The transactions were not considered at arm’s length.
The affiliate was deemed a resident foreign corporation doing business locally.

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.