Company Z is a foreign corporation duly organized and existing under the laws of Singapore. It is licensed to do business in the Philippines as a Regional Operating Headquarters (ROHQ). It renders corporate and administrative services for the sea transportation business of its affiliate, a nonresident foreign corporation doing business outside the Philippines. Company Z's export service include, among others, processing of import and export documentation, procurement, finance and accounting services and information technology-related services. On March 23, 2016, Company Z filed with the CIR, an application for VAT refund of its unutilized and excess creditable input VAT attributable to its zero-rated sales for the four quarters of 2015 in the total amount of P28,004,021. In support thereof, Company Z submitted a letter, dated March 24, 2016, together with the documents and checklist of mandatory requirements for claims of VAT credit/refund. In the rules on application for VAT refund, which of the following is wrong ?  The creditable input VAT should be directly attributable to the zero-rated or effectively zero rated sales. Company Z must be able to sufficiently prove that the input VAT has not been applied against any output tax in any of the succeeding quarters of the following taxable year. Company Z must be VAT registered and the application for refund must be filed within the prescriptive period. There must be a zero-rated or effectively zero-rated sale and input taxes were incurred or paid

SWFT Corp Partner Estates Trusts
42nd Edition
ISBN:9780357161548
Author:Raabe
Publisher:Raabe
Chapter9: Taxation Of International Transactions
Section: Chapter Questions
Problem 44P
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 Company Z is a foreign corporation duly organized and existing under the
laws of Singapore. It is licensed to do business in the Philippines as a
Regional Operating Headquarters (ROHQ). It renders corporate and
administrative services for the sea transportation business of its affiliate,
a nonresident foreign corporation doing business outside the Philippines.
Company Z's export service include, among others, processing of import
and export documentation, procurement, finance and accounting
services and information technology-related services. On March 23, 2016,
Company Z filed with the CIR, an application for VAT refund of its
unutilized and excess creditable input VAT attributable to its zero-rated
sales for the four quarters of 2015 in the total amount of P28,004,021. In
support thereof, Company Z submitted a letter, dated March 24, 2016,
together with the documents and checklist of mandatory requirements
for claims of VAT credit/refund. In the rules on application for VAT refund,
which of the following is wrong ?

 The creditable input VAT should be directly attributable to the zero-rated or effectively zero rated sales.

Company Z must be able to sufficiently prove that the input VAT has not been applied against any output tax in any of the succeeding quarters of the following taxable year.

Company Z must be VAT registered and the application for refund must be filed within the prescriptive period.

There must be a zero-rated or effectively zero-rated sale and input taxes were incurred or paid 

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