Court of Tax Appeals Rejects Agricultural Firm’s P8.4 Million Tax Refund Request

The Court of Tax Appeals (CTA) in Manila has dismissed a claim by MD Rio Vista Agri-Ventures, Inc., based in Compostela Valley, for a tax refund amounting to PHP8.419 million. The decision, detailed in a 25-page document authored by Associate Justice Maria Rowena Modesto-San Pedro and released on December 19, was made by the second division of the tax court, which found the company’s petition to be without merit. The court highlighted that the agricultural firm failed to provide sufficient documentation to substantiate its zero-rated sales transactions, which are necessary to qualify for a VAT refund. The absence of an itemized list meant the court could not verify if the zero-rated sales complied with the required regulations. The CTA emphasized that tax refunds are treated as claims for exemption and must be strictly interpreted against the claimant. The court concluded that the company did not present adequate evidence to justify a refund or the issuance of a tax credit certificate.