Philippine Court Clarifies Input VAT Refunds for Renewable Energy Developer’s Zero-Rated Sales

The Philippine Court of Tax Appeals issued a decision on input VAT refunds for zero-rated sales.
The taxpayer, a renewable energy developer, requested a refund for unutilized input VAT on wind-generated electricity sales.
The Commissioner of Internal Revenue initially denied the refund.
The Court of Tax Appeals, Special Third Division, had previously ruled against the taxpayer.
The Court of Tax Appeals, en banc, overturned these decisions and remanded the case for further review.
Upon remand, the Special Third Division partially granted the taxpayer’s petition.
The court found that the taxpayer’s sales qualified as zero-rated under the National Internal Revenue Code.
Not all sales receipts substantiated the zero rate.

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.