Philippine Court Clarifies Input VAT Refunds on Zero-Rated Sales in Mining Company Case

• The Philippine Court of Tax Appeals issued a decision on input VAT refunds for zero-rated sales.
• A mining company sought a refund on export sales claimed as zero-rated under the National Internal Revenue Code.
• The Bureau of Internal Revenue denied the refund, leading to an appeal.
• The Court of Appeals found the refund claim was timely and the taxpayer was VAT-registered.
• The zero-rated export sale criteria were not met due to missing “zero-rated” statements on invoices and missing shipping documents.
• Remittance amounts in U.S. dollars did not match sales amounts in final invoices.
• Input VAT could not be fully attributed to specific sales and needed proportional allocation based on sales volume.
• The taxpayer failed to prove the input VAT refund claim was not applied against output VAT liability in future quarters.

Source: news.bloombergtax.com

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.

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