COURT OF TAX APPEALS DECISIONS
THE COURT OF TAX APPEALS (CTA) HAS JURISDICTION ONLY OVER DECISIONS OF THE COMMISSIONER OF CUSTOMS (COC), NOT OVER THE LATTER’S INACTION. In this case, petitioner’s claim was based on the alleged inaction of the COC on its protest, which is not appealable to the CTA; moreover, the protest itself was not shown to have been filed in proper form (it failed to specify the ruling protested and lacked proof of payment of protest fees), and no subsequent motion for reconsideration or appealable decision by the COC was established. Consequently, absent a valid appealable decision and compliance with procedural requirements, the CTA had no jurisdiction over the subject matter and was constrained to dismiss the petition. (L.T.J.S. Store, represented by Antonio De Jesus Silva vs. District Collector of Customs, et al., CTA Case No. 10582)
CHANGING THE INVOICE HEADER FROM “CHARGE INVOICE” TO “COMMERCIAL INVOICE” WITHOUT SECURING A NEW PERMIT TO USE COMPUTERIZED ACCOUNTING SYSTEM IS A MERE NOMINAL CHANGE AND DOES NOT CONSTITUTE SYSTEM ENHANCEMENT. A VAT-registered taxpayer claiming zero-rated export sales must substantiate its claim through duly registered VAT invoices containing all required information (including the notation “zero-rated sale”) and proof of actual exportation, such as bills of lading or airway bills; moreover, such invoices must be issued pursuant to a duly authorized system. In this case, although the BIR disallowed the claim on the ground that the taxpayer altered its invoice header from “Charge Invoice” to “Commercial Invoice” without securing a new permit to use CAS, the Court held that the change was merely nominal and did not constitute a “system enhancement” since it neither added value to nor modified the system’s functionality, nor did it result in any change in system release or version number; thus, the existing permit remained valid and the commercial invoices retained their probative value. (MD Isalon Organic Banana Agri-Ventures, Inc. v. CIR, CTA Case No. 10623, July 2, 2025)
SUPPLEMENTARY COMMERCIAL INVOICE GENERATED BY COMPUTERIZED ACCOUNTING SYSTEM IS NOT SUFFICIENT BASIS FOR ZERO-RATING. VAT zero-rating applies only to sales by VAT-registered persons involving the actual shipment of goods from the Philippines to a foreign country, paid in acceptable foreign currency and properly accounted for under Bangko Sentral ng Pilipinas rules, with the sale evidenced by VAT sales invoices and bills of lading or airway bills, and the invoices must be duly registered with the BIR. In this case, the taxpayer issued only Commercial Invoices instead of Charge or VAT Sales Invoices as required under its BIR-authorized Computerized Accounting System (CAS) permit. The Commercial Invoices were merely supplementary documents and outside the approved serial range of its permit to use CAS, and thus could not serve as principal evidence of zero-rated sales. As a result, the taxpayer failed to establish the essential element for zero-rating – that the issuance of valid VAT sales invoices showing actual export sales – and consequently could not substantiate its zero-rated sales. Accordingly, the Court denied the Petition for Review for lack of merit. (MD Davao Agri-Ventures, Inc., v. CIR, CTA Case No. 10625)
AMOUNTS IN THE CERTIFICATE OF INWARD REMITTANCE MUST BE SPECIFICALLY IDENTIFIED, ITEMIZED, OR TRACEABLE TO THE CLAIMED ZERO-RATED EXPORT SALES. A valid zero-rated export sale requires that proceeds be paid in acceptable foreign currency and duly accounted for in accordance with BSP rules. In this case, although the taxpayer submitted bank certifications of inward remittances, the Court found that such documents merely reflected lump-sum remittances without sufficient linkage to specific zero-rated sales transactions, and neither the schedules nor the ICPA Report identified corresponding remittance references or provided a breakdown tracing the payments to the claimed export sales; even attempts to reconcile the reported figures showed discrepancies. Consequently, in the absence of clear, itemized, and traceable proof that the alleged export sales proceeds were received in foreign currency and properly accounted for under BSP rules, petitioner failed to establish compliance with this essential requirement, warranting the denial of its VAT refund claim. (MD Isalon Organic Banana Agri-Ventures, Inc. v. CIR, CTA Case No. 10623, July 2, 2025)
IMPORTATION OF PRESCRIPTION DRUGS AND MEDICINES FOR DIABETES AND HYPERTENSION BEGINNING JANUARY 1, 2020 IS VAT-EXEMPT; VAT MUST NOT BE CLAIMED AS CREDIT IN THE VAT RETURNS. Requisites (1) the medicines are covered by the DOH-FDA approved list; (2) importation occurred within the covered period; (3) the products are qualifying prescription drugs; and (4) the VAT paid was not claimed as input tax credit in VAT returns. In this case, the taxpayer failed to prove compliance with the fourth requirement, as the records showed that the VAT paid was reported in its VAT returns, and significant discrepancies and unreconciled differences between the VAT returns and the ICPA’s findings prevented the Court from determining whether the same amount had already been excluded from input tax credits, raising the possibility of double recovery. Consequently, due to the taxpayer’s failure to clearly establish that the erroneously paid VAT was not utilized as input tax credit, its claim for refund must be denied for lack of sufficient substantiation. (Novartis Healthcare Philippines, Inc. v. CIR, CTA Case No. 10773; see also Astrazeneca Pharmaceuticals (Philippines) Inc., v CIR, CTA Case No. 10725, August 20, 2025)
IN ZERO-RATED SALES, NATURE OF SERVICES MUST BE INDICATED; “INWARD” AS DESCRIPTION IS NOT SUFFICIENT. Services performed in the Philippines by VAT-registered persons for non-resident foreign corporations (NRFCs) or non-resident clients doing business outside the Philippines, paid in acceptable foreign currency and properly accounted for under Bangko Sentral ng Pilipinas (BSP) rules, are subject to zero-percent (0%) VAT, provided the taxpayer strictly complies with all invoicing and substantiation requirements, including issuance of VAT official receipts that clearly indicate the nature of the services rendered. Here, although the taxpayer presented bank certifications and credit advices showing remittances, the VAT official receipts failed to indicate the nature of services rendered, listing only “INWARD” payments, which was insufficient to meet legal standards. As compliance with invoicing and substantiation requirements is mandatory and strictly construed in tax exemption claims, the taxpayer failed to establish entitlement to zero-rating or refund of input taxes for the period claimed. Accordingly, the Petition for Review was denied. (Ibex Global Solutions (Philippines) Inc., v. CIR, CTA Case No. 11005)
SALE TO BOI-REGISTERED ENTITY MUST BE SUPPORTED BY BOI CERTIFICATION; INVOICE ME BE MARKED “ZERO-RATED”. Zero-rated sales by VAT-registered persons are allowed only if specific statutory and regulatory conditions are strictly complied with, including that the sales are made to BOI-registered exporters whose products are 100% exported, supported by a valid BOI certification, and that each sale is covered by a duly registered VAT invoice clearly indicating the term “zero-rated sale.” In this case, the taxpayer failed to establish that its sales qualified as zero-rated or effectively zero-rated because it did not present BOI certifications for its customers, nor did it issue VAT invoices properly marked as “zero-rated,” with the invoices instead showing the amounts as “VATable Sales.” (Monarch Agricultural Products, Inc. v. CIR, CTA Case No. 10376)
REVENUE ISSUANCES
Revenue Memorandum Circular No. 24-2026
Cross-border services are taxable in the Philippines only when the source of income—determined by where the service is performed, completed, or where the benefit is received—is within the country.
| Purpose | Clarifies taxation of cross-border services |
| General Rule | Not all cross-border services are taxable |
| Source of Income | Taxable only if source is within the Philippines |
| Determination of Source | Based on income-producing activity, service completion, or benefit received |
| Assessment Approach | Holistic evaluation of the entire transaction |
| Basis for Taxability | Service delivered, completed, or utilized in PH |
| Burden of Proof | Taxpayer must prove income is from outside PH |
| Proof/Documents | Contracts, sworn statements, tax residency, proof of payment |
Revenue Memorandum Circular No. 20-2026
Pursuant to the Ease of Paying Taxes framework, AITRs must be filed electronically, and for offline eBIRForms users, a screenshot of the submission confirmation serves as valid proof of filing when email confirmation is delayed; thus, taxpayers must retain this screenshot as evidence of compliance.
| Legal Basis | The Circular implements the Ease of Paying Taxes framework requiring electronic filing of AITR through BIR platforms. |
| Filing Requirement | Taxpayers must file AITR electronically, with non-eFPS users utilizing the offline eBIRForms package. |
| Proof of Filing (eBIRForms) | A screenshot of the system-generated pop-up confirming successful submission serves as proof of filing, especially if email confirmation is delayed. |
| Practical Application | Taxpayers using offline eBIRForms should capture and retain the screenshot as evidence when filing and paying taxes. |
BIR DEADLINES FROM APRIL 06, 2026 TO APRIL 19, 2026. A gentle reminder on the following deadlines, as may be applicable:
| DATE | FILING/SUBMISSION |
| April 08, 2026 | SUBMISSION – All Transcript Sheets of Official Register Books (ORBs) used by Dealers/Manufacturers/Toll Manufacturers/Assemblers/Importers of Alcohol Products, Tobacco Products, Petroleum Products, Non-Essential Goods, Sweetened Beverage Products, Mineral Products & Automobiles. Month of March 2026 |
| e-SUBMISSION – Monthly e-Sales Report for All Taxpayers using CRM/POS and/or Other Similar Business Machines whose last digit of 9-digit TIN is Even Number. Month of March 2026 | |
| April 10, 2026 | SUBMISSION – List of Buyers of Sugar Together with a Copy of Certificate of Advance Payment of VAT made by each buyer appearing in the List by a Sugar Cooperative. Month of March 2026 |
| SUBMISSION – Information Return on Releases of Refined Sugar by the Proprietor or Operator of a Sugar Refinery or Mill. Month of March 2026 | |
| e-SUBMISSION – Monthly e-Sales Report for All Taxpayers using CRM/POS and/or Other Similar Business Machines whose last digit of 9-digit TIN is Odd Number. Month of March 2026 | |
| e-FILING & PAYMENT/REMITTANCE (Online/Manual) – BIR Form 2200-M Excise Tax Return for the Amount of Excise Taxes Collected from Payment Made to Sellers of Metallic Minerals. Month of March 2026 | |
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e-FILING & PAYMENT (Online/Manual) – BIR Form 1601-C (Monthly Remittance Return of Income Taxes Withheld on Compensation) – Non-eFPS Filers. Month of March 2026 BIR Form 2200-C (Excise Tax Return for Cosmetic Procedures) with Monthly Summary of Cosmetic Procedures Performed. Month of March 2026 BIR Form 1600-VT (Monthly Remittance Return of Value-Added Tax) and or 1600-PT (Other Percentage Taxes Withheld) and Monthly Alphalist of Payees (MAP) – eFPS & Non-eFPS Filers. Month of March 2026 BIR Form 1606 – (Withholding Tax Remittance Return for Onerous Transfer of Real Property Other Than Capital Asset Including Taxable and Exempt). Month of March 2026 |
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| e-FILING & PAYMENT/REMITTANCE – BIR Form 1600-VT (Monthly Remittance Return of Value-Added Tax) and/or 1600-PT (Other Percentage Taxes Withheld) and BIR Form 1601-C (Monthly Remittance Return of Income Taxes Withheld on Compensation) – National Government Agencies (NGAs). Month of March 2026 | |
| April 11, 2026 | e-FILING – BIR Form 1601-C (Monthly Remittance Return of Income Taxes Withheld on Compensation) – eFPS Filers under Group E. Month of March 2026 |
| April 12, 2026 | e-FILING – BIR Form 1601-C (Monthly Remittance Return of Income Taxes Withheld on Compensation) – eFPS Filers under Group D. Month of March 2026 |
| April 13, 2026 | e-FILING – BIR Form 1601-C (Monthly Remittance Return of Income Taxes Withheld on Compensation) – eFPS Filers under Group C. Month of March 2026 |
| April 14, 2026 | e-FILING – BIR Form 1601-C (Monthly Remittance Return of Income Taxes Withheld on Compensation) – eFPS Filers under Group B. Month of March 2026 |
| April 15, 2026 | REGISTRATION (Online Thru ORUS or Manual) – Permanently Bound Loose-Leaf Books of Accounts/Invoices and Other Accounting Records. Fiscal Year ending March 31, 2026 |
| SUBMISSION – Updated Master List of newly registered taxpayers & taxpayers whose business permits were renewed from LGUs thru its Local Treasurer. Calendar Year ending December 31, 2025 and 2026 Renewals | |
| SUBMISSION – Master List of Retired Businesses from LGU thru its Local Treasurer. Calendar Year ending December 31, 2025 | |
| SUBMISSION – List of Medical Practitioners. For the Quarter ending March 31, 2026 | |
| SUBMISSION – Quarterly List (with Monthly Breakdown) of Contractors of Gov’t. Contracts entered into by the Provinces/Cities/Municipalities/Barangays. For the Quarter ending March 31, 2026 | |
| e-FILING & PAYMENT (Online/Manual) – BIR Form 1702 – RT/1702-EX/1702-MX. Calendar Year ending December 31, 2025 | |
| e-FILING & PAYMENT (Online/Manual) – BIR Form 1707-A (Annual Capital Gains Tax Return For Onerous Transfer of Shares of Stock Not Traded Through the Local Stock Exchange) – by Individual & Corporate Taxpayers. Calendar Year ending December 31, 2025 | |
| e-FILING & PAYMENT (Online/Manual) – BIR Form 2200-M (Excise Tax Return for Mineral Products). For the Quarter ending March 31, 2026 | |
| e-FILING & PAYMENT (Online/Manual) – BIR Forms 1700, 1701, 1701-MS & 1701A – Calendar Year ending December 31, 2025 | |
| e-FILING & e-PAYMENT – BIR Form 1601-C – eFPS Filers under Group A. Month of March 2026 | |
| e-PAYMENT – BIR Form 1601-C – eFPS Filers under Group E, D, C & B. Month of March 2026 | |
| April 16, 2026 | SUBMISSION – Consolidated Return of All Transactions based on the Reconciled Data of Stockbrokers. April 1-15, 2026 |
| April 20, 2026 | SUBMISSION – Quarterly Information on OCWs or OFWs Remittances Exempt from DST furnished by the Local Banks & Non-Bank Money Transfer Agents. For the Quarter ending March 31, 2026 |
| SUBMISSION – Quarterly Report of Printer. For the Quarter ending March 31, 2026 | |
| e-FILING & PAYMENT (Online/Manual) – BIR Form 1600 WP (Remittance Return of Percentage Tax on Winnings and Prizes Withheld by Race Track Operators) – eFPS & Non-eFPS Filers. Month of March 2026 | |
| April 25, 2026 | SUBMISSION – Quarterly Summary List of Sales/Purchases/Importations by a VAT Registered Taxpayers – Non-eFPS Filers. For the Quarter ending March 31, 2026 |
| SUBMISSION – Sworn Statement of Manufacturer’s or Importer’s Volume of Sales of each particular Brand of Alcohol Products, Tobacco Products and Sweetened Beverage Products. For the Quarter ending March 31, 2026 |