The article discusses recent Supreme Court rulings and a BIR circular that simplify VAT zero‑rating and refund procedures for renewable energy developers in the Philippines. It explains that developers no longer need a DOE COE or an ERC COC, and that local suppliers no longer must file zero‑rating applications. The piece also outlines the conditions under which input VAT can be refunded and advises developers to maintain proper registration certificates.
The Supreme Court ruled on 7 August 2024 that a COE from the DOE is not required to avail VAT zero‑rating incentives under RA 9513.
It removed the requirement for local suppliers to file VAT zero‑rating applications for sales to entities with VAT zero‑rating incentives.
No; the Supreme Court ruled on 27 March 2019 that a COC is not required for VAT refunds under the Renewable Energy Law.
They can refund only if the zero‑rated renewable energy sales occur in the same period when the input VAT was paid or incurred.
Get VAT and indirect tax news delivered to your inbox twice a week.
No spam. Unsubscribe anytime.
Tribune · 9 days ago
The city of San Fernando, Pampanga, Philippines has announced that water bills will no longer carry the 12% Value-Added Tax (VAT) starting March 2026. Residents will receive full refunds for VAT collected between 17 November 2025 and February 2026. The measure, announced by Mayor Vilma B. Caluag, aims to reduce household costs and ease living burdens.
Bloomberg Tax · 11 days ago
The Philippine Court of Tax Appeals issued a decision on Feb. 10, 2026 (CTA Case No. 10561) clarifying the validity of assessments for alleged tax deficiencies. The case involved a domestic corporation claiming entitlement to a 5 % preferential gross income tax rate and a 12 % VAT exemption, arguing that the Commissioner of Revenue had incorrectly applied a 30 % threshold for income from Philippine sources outside the Subic Special Economic and Freeport Zone. The court examined whether the sales in question were within the zone and the implications for the tax assessments.
Bloomberg Tax · 18 days ago
On Feb. 2, 2026 the Philippine Court of Tax Appeals ruled that renewable‑energy developers registered with the Department of Energy may zero‑rate purchases and claim input VAT refunds on zero‑rated sales of fuel or power from renewable sources, provided they satisfy substantiation and invoicing requirements. The decision clarified that the Commissioner’s earlier denial was due to missing documentation.
Deloitte Southeast Asia · 21 days ago
The article discusses the impact of the Philippines’ 12% VAT on households and the economy, and examines Senate Bill 1152’s proposal to reduce the rate to 10%. It highlights the fiscal implications, including a projected revenue loss of about P330 billion from 2026 to 2030, and the broader effects on consumer spending and government finances.
Bloomberg Tax · 25 days ago
The Philippine Court of Tax Appeals (CTA) issued a decision on Jan. 23, 2026 (Case No. 10626) clarifying the treatment of unutilized input VAT refunds on zero‑rated export sales. The decision addresses the denial by the Commissioner of Internal Revenue, which was based on a failure to substantiate the claim and invoices not covered by the approved Permit to Use Computerized Accounting System (PTUCAS).
Bloomberg Tax · 28 days ago
The Philippine Court of Tax Appeals issued a decision (CTA EB No. 2951) on Jan. 16, 2026 clarifying the treatment of unutilized input VAT refunds on zero‑rated export sales. The court partially granted a refund claim by a corporation engaged in export sales, after the Commissioner of Internal Revenue denied the request for lack of proof that service recipients were not doing business in the Philippines.
