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.
On Feb 2 2026, the Court ruled that renewable energy developers registered with the Department of Energy are entitled to zero‑rate purchases and can claim input VAT refunds on zero‑rated sales of fuel or power from renewable sources, provided they meet substantiation and invoicing requirements.
The decision covered CTA Case Nos. 9455, 9500, 9529, and 9555.
The Commissioner denied the claim because the taxpayer failed to meet the required substantiation and invoicing requirements for input VAT refunds.
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Deloitte Southeast Asia · 4 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 · 8 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 · 11 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.
Bloomberg Tax · 12 days ago
On 21 January 2026 the Philippine Court of Tax Appeals issued CTA Case No. 10505, clarifying that unutilized input VAT refunds on zero‑rated sales must be substantiated with an administrative refund claim and proof of entitlement. The decision confirms that the Internal Revenue Commissioner’s denial of a 2018 excess input VAT refund was based on the taxpayer’s failure to meet these requirements.
Manila Times · 13 days ago
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.
Bloomberg Tax · 13 days ago
The Philippine Court of Tax Appeals issued a decision on Jan. 19, 2026 (Case No. 10607) clarifying the validity of assessments for alleged tax deficiencies. The ruling covers a range of taxes—including income tax, VAT, expanded withholding tax, and others—and finds that due process was not violated because the Final Decision on the Disputed Assessment (FDDA) stated the relevant facts. The decision provides guidance on how assessments are evaluated for due process compliance.
