The Manila Times opinion piece explains how the Supreme Court’s February 4 2025 ruling in the Subic Bay Freeport case clarified that domestic market enterprises (DMEs) are entitled to VAT zero‑rating under the Create Act, overturning earlier BIR issuances that excluded them. It also outlines the conditions under which DMEs can still claim the benefit under the newer Create More law, namely high‑value DMEs with significant investment capital or export sales, and stresses that purchases must be directly attributable to the registered project. The article advises businesses in freeports and ecozones to update their ERP systems, document eligibility, and align procurement processes to avoid disputes.
The Court held that DMEs are entitled to VAT zero‑rating under the Create Act, and the exclusion of DMEs in earlier BIR issuances was void.
High‑value DMEs—those with investment capital over P15 billion in import‑substituting sectors or prior‑year export sales of at least $100 million—can still avail of the benefit under Create More.
Purchases must be “directly attributable” to the registered project or activity, requiring operational evidence of usage.
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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.
