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Philippine Court Denies VAT Refund for Ship Broker Due to Insufficient Documentation and Proof

  • The Philippine Court of Tax Appeals issued a decision on March 25 in CTA Case No. EB 2788.
  • The case involved an input VAT refund assessment on zero-rated transactions.
  • The taxpayer, a company acting as a representative or broker of ships, sought a refund for unutilized input VAT.
  • The Bureau of Internal Revenue denied the refund due to invoicing violations and insufficient documentation.
  • The Court of Appeals, Third Division, denied the taxpayer’s appeal, citing failure to prove services were performed in the Philippines.
  • The Court of Appeals, En Banc, upheld the decision, noting lack of necessary documentation and evidentiary support.
  • The “manning agreements” did not establish that services were performed in the Philippines.

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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