The Court of Tax Appeals (CTA) has upheld the denial of a P59.81‑million value‑added tax refund claim filed by Zuellig Pharma Asia Pacific Ltd. Phils. ROHQ.
In a ruling issued on July 9, the tax court reaffirmed an earlier decision that rejected the company’s request for excess and unused input VAT for 2011.
The court found that Zuellig Pharma could not demonstrate that proceeds from its zero‑rated sales were paid in acceptable foreign currency or that they were properly accounted for under Bangko Sentral ng Pilipinas regulations.
Additionally, the company’s VAT official receipts did not meet the invoicing requirements set out in the National Internal Revenue Code, and about P2.88 million of zero‑rated sales lacked the necessary certificates of inward remittance. The court deemed this omission fatal to the refund claim.
Arguments based on VAT neutrality and an independent accountant’s findings were rejected, as the court emphasized that strict compliance with documentary requirements is mandatory in VAT refund cases.
