BIR Bars Foreign Tech Giants from Using Tax Treaties to Dodge VAT

The BIR said foreign digital service providers cannot use tax treaties to evade the Philippines’ 12% VAT, since treaties apply only to income taxes.
VAT exemptions or zero-rating for digital services come from the Philippine Tax Code, not from international treaties, but providers must still register and file returns.
In B2B cross-border cases, the Philippine company is responsible for remitting VAT under a reverse charge system.
For online travel, hospitality, and digital ads, VAT applies only to the service-fee portion or to transactions paid by Philippine entities, not necessarily to gross booking value or audience location.
Existing subscriptions that began before the law took effect must still have 12% VAT computed and paid on the remaining months.

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.