Rema Tip Top Philippines, Inc. v. Commissioner of Internal Revenue

FIRST DIVISION [C.T.A. CASE NO. 9836. May 25, 2021.] REMA TIP TOP PHILIPPINES, INC. , petitioner , vs. COMMISSIONER OF INTERNAL REVENUE , respondent . DECISION DEL ROSARIO , P.J p : Before this Court is a Petition for Review filed on May 15, 2018 by petitioner Rema Tip Top Philippines, Inc. against respondent Commissioner of Internal Revenue (CIR), praying for the refund of Five Million Eight Hundred Ninety-Seven Thousand Nine Hundred Seventeen and 11/100 Pesos (P5,897,917.11) representing its input Value-Added Tax (VAT) allegedly attributable or allocated to its zero-rated sales for taxable year (TY) 2016. THE PARTIES Petitioner Rema Tip Top Philippines, Inc. is a corporation duly organized and existing under Philippine laws, with principal business address at Unit 502 Richmonde Plaza Ortigas, San Miguel Ave. cor. Lourdes St., Pasig City. 1 It is registered with the Bureau of Internal Revenue (BIR) as a VAT taxpayer with Tax Identification No. (TIN) 008-042-655-000 under Certificate of Registration No. OCN3RC0000758904. 2 Respondent, on the other hand, is the duly appointed Commissioner of the BIR, with principal office at the 5th Floor, BIR National Office Building, Agham Road, Diliman, Quezon City. 3 THE FACTS Petitioner was incorporated on May 9, 2011. 4 Its primary purpose as stated in its Amended Articles of Incorporation 5 is as follows: "To operate, conduct and carry on the business of engaging in any construction or construction-related work on commercial or industrial facilities to maximize the operational readiness thereof by employing or installing corrosion and wear and tear protection using techniques, now employed or to be developed, and taking advantage of versatile properties or materials such as, but not limited to, rubber, polyurethane, polytetrafluor ethylene, polyethylene, aluminum oxide ceramics and plyurea; to make, execute, and receive contracts or assignments or delegations of contracts for or relating to or connected with the business of providing corrosion and wear and tear protection and other commercial and industrial solutions; to manufacture, import or otherwise acquire, and to furnish all other tools and equipment connected with or required for the business; to manufacture, produce, adapt, prepare, import, and deal in any materials, articles, or things incidental to, or required for, or useful in connection with, any of such activities; and generally to carry on any other activities which can be advantageously pursued in conjunction with or incidental to any of the above purposes." CAIHTE On July 12, 2017, petitioner filed with the BIR its Amended Quarterly VAT Return for the first, second, third and fourth quarters of TY 2016. 6 On April 2, 2018, petitioner filed with respondent, through Revenue District Office (RDO) No. 43, an administrative claim for refund of input VAT attributable to zero-rated sales made in TY 2016. 7 On April 12, 2018, petitioner received a Letter dated April 10, 2018 from RDO No. 43 denying its administrative claim for refund. 8 In view of the denial of its administrative claim, petitioner filed the present Petition for Review before the Court on May 15, 2018. 9 On July 13, 2018, within the extended period, 10 respondent filed his Answer, 11 with the following special and affirmative defenses: (1) petitioner's claim for tax refund was correctly denied for its failure to submit the documents required in Revenue Memorandum Order (RMO) 54-2014; (2) petitioner failed to comply with the invoicing and accounting requirements under the National Internal Revenue Code (NIRC); (3) the Financial Statements of petitioner did not show that it recorded nor earmarked the alleged unutilized input taxes subject of the present claim; (4) claimant has the burden of proof to establish the factual basis of the claim for tax credit or refund; and (5) tax refunds are in the nature of tax exemptions which are construed strictissimi juris against the taxpayer and liberally in favor of the government. On November 5, 2018, both the respondent's Pre-Trial Brief 12 and petitioner's Pre-Trial Brief 13 were filed. The Pre-Trial Conference was held on January 17, 2019. 14 On April 11, 2019, the Court issued the Pre-Trial Order 15 thereby terminating the pre-trial. Upon motion 16 of petitioner, the Court commissioned Ms. Ma. Theresa R. Dela Roca, as Independent Certified Public Accountant (ICPA), on April 11, 2019. 17 During trial, petitioner presented testimonial and documentary evidence. It presented the following witnesses: Ms. Jennilyn U. Gaanan, 18 petitioner's Director, Treasurer and Chief Financial Officer; and Ms. Ma. Theresa R. Dela Roca, 19 the Court-commissioned ICPA. Petitioner's Formal Offer of Documentary Exhibits 20 was filed through registered mail on October 25, 2019. Petitioner's exhibits were admitted in evidence in the Resolution 21 dated February 26, 2020, except those exhibits the originals of which were not presented by petitioner for comparison, were not found in the records, and were not identified. During the hearing on September 3, 2019, respondent manifested that he has no evidence to present. 22 Petitioner filed its Memorandum 23 on July 1, 2020, while respondent failed to file his memorandum despite due notice. 24 The case was submitted for decision on July 22, 2020. 25 THE ISSUE The parties stipulated the following issue 26 for resolution: "Whether petitioner is entitled to a refund of its alleged input VAT attributable or allocated to zero-rated sales made during the TY 2016 in the aggregate amount of P5,897,917.11." DETACa PARTIES' ARGUMENTS Petitioner argues that: (i) it is entitled to a refund of input VAT attributable to zero-rated sales made in TY 2016; (ii) under Section 106 (A) (2) (a) (5) and 108 (B) (3) of the NIRC of 1997, as amended, sales by a VAT-registered taxpayer to enterprises registered with the Philippine Economic Zone Authority (PEZA) or the Board of Investments (BOI) are subject to zero-rated VAT; (iii) it has complied with the requirements for a claim for VAT refund under Section 112 (A) of the NIRC of 1997, as amended; (iv) the supporting documents submitted by petitioner for its administrative claim for refund are deemed complete. On the other hand, respondent in his Answer counter-argues that: (i) petitioner's claim for tax refund has no basis since its request was denied for petitioner's failure to submit the documents required in RMO No. 54-2014; (ii) petitioner failed to comply with the invoicing and accounting compliance required by the NIRC of 1997, as amended; and, (iii) the Financial Statements of petitioner did not show that it recorded nor earmarked the alleged unutilized input taxes that is the subject of the present claim; and, (iv) the claimant has the burden of proof to establish the factual basis of the claim for tax credit or refund since tax refunds are in the nature of tax exemptions which are construed strictissimi juris against the taxpayer and liberally in favor of the government. THE COURT'S RULING Petitioner anchors its claim for refund on Section 112 (A), in relation to Section 112 (C), of the NIRC of 1997, as amended by R.A. No. 10963 27 [otherwise known as the Tax Reform for Acceleration and Inclusion Act (TRAIN law)], viz. : "SEC. 112. Refunds or Tax Credits of Input Tax . (A) Zero-Rated or Effectively Zero-Rated Sales . Any VAT-registered person, whose sales are zero-rated or effectively zero-rated may, within two (2) years after the close of the taxable quarter when the sales were made, apply for the issuance of a tax credit certificate or refund of creditable input tax due or paid attributable to such sales, except transitional input tax, to the extent that such input tax has not been applied against output tax: Provided, however , That in the case of zero-rated sales under Section 106(A)(2)(a)(1), (2) and (b) and Section 108 (B)(1) and (2), the acceptable foreign currency exchange proceeds thereof had been duly accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP): Provided, further , That where the taxpayer is engaged in zero-rated or effectively zero-rated sale and also in taxable or exempt sale of goods of properties or services, and the amount of creditable input tax due or paid cannot be directly and entirely attributed to any one of the transactions, it shall be allocated proportionately on the basis of the volume of sales: Provided, finally , That for a person making sales that are zero-rated under Section 108 (B)(6), the input taxes shall be allocated ratably between his zero-rated and non-zero-rated sales. xxx xxx xxx (C) Period within which Refund of Input Taxes shall be Made . In proper cases, the Commissioner shall grant a refund for creditable input taxes within ninety (90) days from the date of submission of the official receipts or invoices and other documents in support of the application filed in accordance with Subsections (A) and (B) hereof: Provided , That should the Commissioner find that the grant of refund is not proper, the Commissioner must state in writing the legal and factual basis for the denial. In case of full or partial denial of the claim for tax refund, the taxpayer affected may, within thirty (30) days from the receipt of the decision denying the claim, appeal the decision with the Court of Tax Appeals: Provided, however , That failure on the part of any official, agent, or employee of the BIR to act on the application within the ninety (90)-day period shall be punishable under Section 269 of this Code." Based on the aforequoted provisions of law, a claimant must satisfy the following requisites in order to be entitled to a refund or tax credit of unutilized input VAT attributable to zero-rated sales: 1. the taxpayer-claimant must be VAT-registered; 2. the claim was filed within the prescribed periods both in the administrative and judicial levels; 3. there must be zero-rated or effectively zero-rated sales; 4. input taxes were incurred or paid; 5. such input taxes are attributable to zero-rated or effectively zero-rated sales; and, ATICcS 6. said input taxes were not applied against any output VAT liability. First Requisite: Petitioner is a VAT-registered entity Petitioner has proven its compliance with the first requisite through its BIR Certificate of Registration which shows that it is a VAT-registered taxpayer with TIN No. 008-042-655-000. 28 Second Requisite: Petitioner's administrative and judicial claims for refund were timely filed Anent petitioner's administrative claim, Section 112 (A) of the NIRC of 1997, as amended, specifically requires that the taxpayer's application for refund or issuance of TCC of unutilized and/or excess input VAT arising from its domestic purchases of services and importation of goods other than capital goods, which are attributable to its zero-rated sales, must be made within two (2) years after the close of the taxable quarter when the sales were made. Petitioner's claim for refund or issuance of TCC covers the four (4) quarters of TY 2016 which closed on March 31, 2016, June 30, 2016, September 30, 2016 and December 31, 2016, respectively. Thus, it had two (2) years from the said dates or until March 31, 2018, June 30, 2018, September 30, 2018 and December 31, 2018, respectively, within which to file its administrative claim for the quarters concerned. Thus, the filing of the administrative claim for refund or tax credit for the four quarters of TY 2016 with the BIR, on April 2, 2018, fell within the respective two-year prescriptive period. As shown below, petitioner timely filed its administrative claim for the four (4) quarters of TY 2016: Taxable Quarter (TY 2016) Quarter End Last day of filing Administrative Claim for Refund Date of Filing of Administrative Claim for Refund 1st Quarter March 31, 2016 April 2, 2018 29 April 2, 2018 2nd Quarter June 30, 2016 June 30, 2018 3rd Quarter September 30, 2016 September 30, 2018 4th Quarter December 31, 2016 December 31, 2018 Anent petitioner's judicial claim for refund or issuance of TCC, Section 11 of Republic Act No. (RA) 1125, 30 as amended by RA No. 9282, 31 provides the period of limitation within which to file an appeal before this Court, viz. : "SEC. 11. Who May Appeal; Mode of Appeal; Effect of Appeal. Any party adversely affected by a decision, ruling or inaction of the Commissioner of Internal Revenue, the Commissioner of Customs, the Secretary of Finance, the Secretary of Trade and Industry or the Secretary of Agriculture or the Central Board of Assessment Appeals or the Regional Trial Courts may file an appeal with the CTA within thirty (30) days after the receipt of such decision or ruling or after the expiration of the period fixed by law for action as referred to in Section 7(a)(2) herein. Appeal should be made by filing a petition for review under a procedure analogous to that provided for under Rule 42 of the 1997 Rules of Civil Procedure with the CTA within thirty (30) days from the receipt of the decision or ruling or in the case of inaction as herein provided, from the expiration of the period fixed by law to act thereon. x x x" As aforestated, petitioner filed its administrative claim for refund or issuance of TCC representing its excess and/or unutilized input VAT for TY 2016 in the amount of P5,897,917.11 on April 2, 2018. Within the 90-day period to act on petitioner's administrative claim for refund, the CIR denied petitioner's administrative claim in a Letter dated April 10, 2018. TIADCc Since petitioner received the aforesaid Letter on April 12, 2018, petitioner had thirty (30) days from said date or until May 12, 2018 within which to appeal to the CTA. Considering, however that May 12, 2018 fell on a Saturday and May 14, 2018 was declared as a non-working holiday, petitioner had until May 15, 2018, the next working day, within which to file its judicial claim for refund. The Petition for Review filed on May 15, 2018 was therefore filed within the reglementary period to appeal. Thus, the Court has jurisdiction to take cognizance of the Petition for Review. Third Requisite: Petitioner had zero-rated sales during the subject period in the amount of P62,449,305.68 Sales of Goods and Services to Entities Registered with PEZA and BOI whose products are 100% exported Petitioner maintains that its sales of goods and services to entities registered with PEZA and BOI during the period October 1, 2015 to March 31, 2016 are subject to zero percent (0%) VAT, pursuant to Sections 106 (A) (2) (a) (3), (5) and (c) and 108 (B) (3) of the NIRC of 1997, as amended. The pertinent provisions of Sections 106 (A) (2) (a) (3), (5) and (c) and 108 (B) (3) of the NIRC of 1997, as amended, state: " SEC. 106. Value-Added Tax on Sale of Goods or Properties . (A) Rate and Base of Tax x x x xxx xxx xxx (2) The following sales by VAT-registered persons shall be subject to zero percent (0%) rate: (a) Export Sales . The term 'export sales' means: xxx xxx xxx (3) Sale of raw materials or packaging materials to export oriented enterprise whose export sales exceed seventy percent (70%) of total annual production; xxx xxx xxx (5) Those considered export sales under Executive Order No. 226, otherwise known as the Omnibus Investment Code of 1987, and other special laws . xxx xxx xxx (1) Sales to persons or entities whose exemption under special laws or international agreements to which the Philippines is a signatory effectively subjects such sales to zero rate." (Boldfacing supplied) " SEC. 108. Value-Added Tax on Sale of Services and Use or Lease of Properties . (A) Rate and Base of Tax . xxx xxx xxx (B) Transactions Subject to Zero Percent (0%) Rate . The following services performed in the Philippines by VAT-registered persons shall be subject to zero percent (0%) rate: xxx xxx xxx (3) Services rendered to persons or entities whose exemption under special laws or international agreements to which the Philippines is a signatory effectively subjects the supply of such services to zero percent (0%) rate;" (Boldfacing supplied) Relative thereto, Sections 4.106-5 and 4.108-5 of Revenue Regulations (RR) No. 16-2005, as amended by RR No. 04-07, also provide: " SEC. 4.106-5. Zero-Rated Sales of Goods or Properties . x x x The following sales by VAT-registered persons shall be subject to zero percent (0%) rate: SDAaTC (a) Export sales . 'Export Sales' shall mean: xxx xxx xxx (5) Transactions considered export sales under Executive Order No. 226, otherwise known as the Omnibus Investments Code of 1987, and other special laws. 'Considered export sales under Executive Order No. 226' shall mean the Philippine port F.O.B. value determined from invoices, bills of lading, inward letters of credit, landing certificates, and other commercial documents, of export products exported directly by a registered export producer, or the net selling price of export products sold by a registered export producer to another export producer, or to an export trader that subsequently exports the same; Provided, That sales of export products to another producer or to an export trader shall only be deemed export sales when actually exported by the latter, as evidenced by landing certificates or similar commercial documents; Provided, further, That pursuant to EO 226 and other special laws, even without actual exportation, the following shall be considered constructively exported: (1) sales to bonded manufacturing warehouses of export-oriented manufacturers; (2) sales to export processing zones pursuant to Republic Act (RA) Nos. 7916, as amended, 7903, 7922 and other similar export processing zones; (3) sale to enterprises duly registered and accredited with the Subic Bay Metropolitan Authority pursuant to RA 7227 ; (4) sales to registered export traders operating bonded trading warehouses supplying raw materials in the manufacture of export products under guidelines to be set by the Board in consultation with the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC); (5) sales to diplomatic missions and other agencies and/or instrumentalities granted tax immunities, of locally manufactured, assembled or repacked products whether paid for in foreign currency or not. For purposes of zero-rating, the export sales of registered export traders shall include commission income. The exportation of goods on consignment shall not be deemed export sales until the export products consigned are in fact sold by the consignee: and Provided, finally , that sales of goods, properties or services made by a VAT-registered supplier to a BOI-registered manufacturer/producer whose products are 100% exported are considered export sales . A certification to this effect must be issued by the Board of Investment (BOI) which shall be good for one year unless subsequently re-issued by the BOI. xxx xxx xxx (b) 'Sales to Persons or Entities Deemed Tax-exempt under Special Law or International Agreement' Sales of goods or property to persons or entities who are tax-exempt under special laws, e.g. , sales to enterprises duly registered and accredited with the Subic Bay Metropolitan Authority (SBMA) pursuant to R.A. No. 7227, sales to enterprises duly registered and accredited with the Philippine Economic Zone Authority (PEZA) or international agreements to which the Philippines is signatory, such as, Asian Development Bank (ADB), International Rice Research Institute (IRRI), etc., shall be effectively subject to VAT at zero-rate." (Boldfacing supplied) " SEC. 4.108-5. Zero-Rated Sale of Services . xxx xxx xxx (b) Transactions Subject to Zero Percent (0%) VAT Rate . The following services performed in the Philippines by a VAT-registered person shall be subject to zero percent (0%) VAT rate: xxx xxx xxx (3) Services rendered to persons or entities whose exemption under special laws or international agreements to which the Philippines is a signatory effectively subjects the supply of such services to zero percent (0%) rate;" (Boldfacing supplied) RA No. 7916, as amended by RA No. 8748, otherwise known as "The Special Economic Zone Act of 1995," provides for the creation of the PEZA and treatment of special economic zones (Ecozones) as separate customs territory, to wit: "REPUBLIC ACT NO. 7916 (AS AMENDED BY REPUBLIC ACT NO. 8748) AN ACT PROVIDING FOR THE LEGAL FRAMEWORK AND MECHANISMS FOR THE CREATION, OPERATION, ADMINISTRATION, AND COORDINATION OF SPECIAL ECONOMIC ZONES IN THE PHILIPPINES, CREATING FOR THIS PURPOSE, THE PHILIPPINE ECONOMIC ZONE AUTHORITY (PEZA) AND FOR OTHER PURPOSES. acEHCD xxx xxx xxx SEC. 8. ECOZONE to be Operated and Managed as Separate Customs Territory . The ECOZONE shall be managed and operated by the PEZA as separate customs territory . The PEZA is hereby vested with the authority to issue certificates of origin for products manufactured or processed in each ECOZONE in accordance with the prevailing rules of origin, and the pertinent regulations of the Department of Trade and Industry and/or the Department of Finance. xxx xxx xxx SEC. 24. Exemption from National and Local Taxes . Except for real property taxes on land owned by developers, no taxes, local and national, shall be imposed on business establishments operating within the ECOZONE. x x x" (Boldfacing supplied) Since an Ecozone is treated as a foreign territory by legal fiction, sales of goods and services made by a VAT-registered person in the Philippine customs territory to an entity registered and operating within an Ecozone are considered exports to a foreign country subject to 0% VAT. This was elucidated by the Supreme Court in Commissioner of Internal Revenue vs. Toshiba Information Equipment (Phils.), Inc. , 32 to wit: "This Court agrees, however, that PEZA-registered enterprises, which would necessarily be located within ECOZONES, are VAT-exempt entities, not because of Section 24 of Rep. Act No. 7916, as amended, which imposes the five percent (5%) preferential tax rate on gross income of PEZA-registered enterprises, in lieu of all taxes; but, rather, because of Section 8 of the same statute which establishes the fiction that ECOZONES are foreign territory. x x x An ECOZONE or a Special Economic Zone has been described as . . . [S]elected areas with highly developed or which have the potential to be developed into agro-industrial, industrial, tourist, recreational, commercial, banking, investment and financial centers whose metes and bounds are fixed or delimited by Presidential Proclamations. An ECOZONE may contain any or all of the following: industrial estates (IEs), export processing zones (EPZs), free trade zones and tourist/recreational centers. The national territory of the Philippines outside of the proclaimed borders of the ECOZONE shall be referred to as the Customs Territory. Section 8 of Rep. Act No. 7916, as amended, mandates that the PEZA shall manage and operate the ECOZONES as a separate customs territory; thus, creating the fiction that the ECOZONE is a foreign territory. As a result, sales made by a supplier in the Customs Territory to a purchaser in the ECOZONE shall be treated as an exportation from the Customs Territory. Conversely, sales made by a supplier from the ECOZONE to a purchaser in the Customs Territory shall be considered as an importation into the Customs Territory. Given the preceding discussion, what would be the VAT implication of sales made by a supplier from the Customs Territory to an ECOZONE enterprise? The Philippine VAT system adheres to the Cross Border Doctrine, according to which, no VAT shall be imposed to form part of the cost of goods destined for consumption outside of the territorial border of the taxing authority. Hence, actual export of goods and services from the Philippines to a foreign country must be free of VAT; while, those destined for use or consumption within the Philippines shall be imposed with ten percent (10%) VAT." Meanwhile, pursuant to RMO No. 9-2000, 33 sales of goods, properties or services made by a VAT-registered supplier to a BOI registered entity whose products are 100% exported shall be accorded automatic VAT zero-rating, subject to the reportorial and documentary requirements prescribed under Section 3 thereof, thus: "SECTION 3. Sales of goods, properties or services made by a VAT registered supplier to a BOI-registered exporter shall be accorded automatic zero-rating, i.e., without necessity of applying for and securing approval of the application for zero-rating as provided in Revenue Regulations No. 7-95, subject to the following conditions: (1) The supplier must be VAT-registered; SDHTEC (2) The BOI-registered buyer must likewise be VAT-registered; (3) The buyer must be a BOI-registered manufacturer/producer whose products are 100% exported. For this purpose, a Certification to this effect must be issued by the Board of Investments (BOI) and which certification shall be good for one year unless subsequently re-issued by the BOI; (4) The BOI-registered buyer shall furnish each of its suppliers with a copy of the aforementioned BOI Certification which shall serve as authority for the supplier to avail of the benefits of zero-rating for its sales to said BOI-registered buyers ; and (5) The VAT-registered supplier shall issue for each sale to BOI-registered manufacturer/exporters a duly registered VAT invoice with the words 'zero-rated' stamped thereon in compliance with Sec. 4.108-1(5) of Revenue Regulations No. 7-95. The supplier must likewise indicate in the VAT-invoice the name and BOI-registry number of the buyer." (Boldfacing supplied) Based on the foregoing, sales of goods and services by a VAT-registered taxpayer, such as petitioner, to entities located in the ECOZONES, as well as to BOI-registered entities whose products are 100% exported, are considered "export sales" subject to VAT zero-rating pursuant to Sections 106 (A) (2) (a) (3), (5) and (c) and 108 (8) (3) of the NIRC of 1997, as amended, and as implemented by Sections 4.106-5 and 4.108-5 of RR No. 16-05, as amended. To prove that its clients are duly registered with the PEZA and the BOI, petitioner submitted various certifications issued by the said agencies. Listed below are the clients of petitioner registered with the PEZA and the BOI: Clients Certifying Body Proof of VAT Zero-rating Exhibit Certification Period FCF MINERALS CORPORATION BOI Confirmation Letter from BOI dated April 29, 2016; Certificate No. 2016-011 P-28 to P-28.1 January 1 to December 31, 2016 CORAL BAY NICKEL CORPORATION (CBNC) PEZA Certificate No. 2016-0856 P-29 2016 TAGANITO HPAL NICKEL CORPORATION (THPAL) PEZA Certificate No. 2016-0534 P-30 2016 Upon review of the certifications issued by the PEZA and the BOI, the Court considers the sales of goods and services by petitioner to the above-listed clients subject to VAT zero-rating. Sales of Service to Non-resident Foreign Corporations (NRFCs) Petitioner alleges that out of its zero-rated sales aggregating in the amount of P83,178,005.10 for the four quarters of TY 2016, P3,309,019.20 pertains to sale of services to NRFCs, as follows: Customers 3rd Quarter 4th Quarter Total Rema Tip Top Malaysia BHD PTY P1,023,663.08 - P1,023,663.08 Rema Tip Top Malaysia SDN BHD - 2,285,356.12 2,285,356.12 Total P1,023,663.08 2,285,356.12 P3,309,019.20 Section 108 (B) (2) of the NIRC of 1997, as amended, provides: "SEC. 108. Value-Added Tax on Sale of Services and Use or Lease of Properties . (A) x x x (B) Transactions Subject to Zero Percent (0%) Rate . The following services performed in the Philippines by VAT-registered persons shall be subject to zero percent (0%) rate: AScHCD (1) Processing, manufacturing or repacking goods for other persons doing business outside the Philippines which goods are subsequently exported, where the services are paid for in acceptable foreign currency and accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP); (2) Services other than those mentioned in the preceding paragraph rendered to a person engaged in business conducted outside the Philippines or to a non-resident person not engaged in business who is outside the Philippines when the services are performed, the consideration for which is paid for in acceptable foreign currency and accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP) ; x x x" (Boldfacing supplied) Certain essential elements must be present in order for a sale or supply of services to be subject to VAT rate of zero percent (0%) under Section 108 (B) (2) of the NIRC of 1997, as amended, to wit: 1. The recipient of the services is a foreign corporation, and the said corporation is doing business outside the Philippines, or is a non-resident person not engaged in business who is outside the Philippines when the services are performed; 34 2. The payment for such services should be in acceptable foreign currency accounted for in accordance with the BSP rules; 35 3. The services fall under any of the categories under Section 108 (B) (2), 36 or simply, the services rendered should be other than "processing, manufacturing or repacking goods"; 37 and 4. The services must be performed in the Philippines by a VAT-registered person. 38 To prove that its clients are NRFC for purposes of VAT zero-rating under Section 108 (B) (2) of the NIRC of 1997, as amended, petitioner must establish that: (1) the client was established under the laws of a foreign country; and, (2) it is not engaged in trade or business in the Philippines. To be sure, there must be sufficient proof of both of these requirements to establish that the clients are foreign corporations AND are not doing business in the Philippines. 39 Thus, petitioner must submit for each NRFC client, at the very least, both: (1) the SEC Certificate of Non-Registration of Corporation/Partnership; AND (2) Proof of Certificate/Articles of Foreign Incorporation/Association showing the state/province/country where the entity was organized. 40 The SEC Certificate of Non-Registration shows that the foreign client is not engaged in trade or business in the Philippines. On the other hand, the Certificate/Articles of Foreign Incorporation/Association proves that the client was established under the laws of a foreign country. Together, these two (2) documents prove the two (2) requisites necessary to establish the NRFC status of a client. Upon review of the records, it is shown that petitioner failed to present the two (2) required documents to prove the NRFC status of its foreign clients. Thus, the entire amount of P3,309,019.20 representing sales to alleged NRFCs, detailed below, shall be disallowed: OR/SI Exhibit OR/SI Date Customer Amount 3rd Quarter OR 1032 P-4814 8/25/16 REMA TIP TOP MALAYSIA BHD PTY P506,653.13 OR 1042 P-247 9/23/16 REMA TIP TOP MALAYSIA BHD PTY 517,009.95 Subtotal 3rd Quarter 1,023,663.08 4th Quarter OR 1045 P-267 10/21/16 REMA TIP TOP MALAYSIA SDN BHD 643,453.72 OR 1050 P-296 11/10/16 REMA TIP TOP MALAYSIA SDN BHD 705,561.54 OR 1055 P-308 12/22/16 REMA TIP TOP MALAYSIA SDN BHD 63,792.04 OR 1055 P-309 12/22/16 REMA TIP TOP MALAYSIA SDN BHD 250,782.37 OR 1053 P-310 12/16/16 REMA TIP TOP MALAYSIA SDN BHD 621,766.45 Subtotal 4th Quarter 2,285,356.12 Total P3,309,019.20 Disallowed Zero-rated Sales In its 1st, 2nd, 3rd and 4th Quarterly VAT Returns 41 for TY 2016, petitioner reported total sales of P97,802,307.14 which included zero-rated sales in the amount of P83,178,005.10, broken down as follows: caITAC Sales 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total VATable Sales P3,570,726.25 P3,147,236.77 P4,634,724.97 P3,271,614.05 P14,624,302.04 Zero-rated Sales 22,759,452.94 19,064,944.08 20,776,007.25 20,577,600.83 83,178,005.10 Total P26,330,179.19 P22,212,180.85 P25,410,732.22 P23,849,214.88 P97,802,307.14 The Court shall then examine whether the reported zero-rated sales of petitioner complied with the invoicing requirements under Section 113 (A) (1) and (2), (B) (1), (2) (c) and (3) of the NIRC of 1997, as amended, viz. : " SEC. 113. Invoicing and Accounting Requirements for VAT-Registered Persons . (A) Invoicing Requirements. A VAT-registered person shall issue: (1) A VAT invoice for every sale, barter or exchange of goods or properties; and (2) A VAT official receipt for every lease of goods or properties, and for every sale, barter or exchange of services. (B) Information Contained in the VAT Invoice or VAT Official Receipt The following information shall be indicated in the VAT invoice or VAT official receipt: (1) A statement that the seller is a VAT-registered person, followed by his Taxpayer's Identification Number (TIN); (2) The total amount which the purchaser pays or is obligated to pay to the seller with the indication that such amount includes the value-added tax: Provided , That: xxx xxx xxx (c) If the sale is subject to zero percent (0%) value-added tax, the term 'zero-rated sale' shall be written or printed prominently on the invoice or receipt; xxx xxx xxx (3) The date of transaction, quantity, unit cost and description of the goods or properties or nature of the service; x x x" The same requirements are provided for under Section 4.113-1 (A) (1) and (2), (8) (1) and (2) (c) of RR No. 16-2005, as follows: " SEC. 4.113-1. Invoicing Requirements . (A) A VAT-registered person shall issue: (1) A VAT invoice for every sale, barter or exchange of goods or properties; and (2) A VAT official receipt for every lease of goods or properties, and for every sale, barter or exchange of services. Only VAT-registered persons are required to print their TIN followed by the word 'VAT' in their invoice or official receipts. Said documents shall be considered as a 'VAT Invoice' or VAT official receipt. All purchases covered by invoices/receipts other than VAT Invoice/VAT Official Receipt shall not give rise to any input tax. VAT invoice/official receipt shall be prepared at least in duplicate, the original to be given to the buyer and the duplicate to be retained by the seller as part of his accounting records. ICHDca (B) Information contained in VAT invoice or VAT official receipt. The following information shall be indicated in VAT invoice or VAT official receipt: (1) A statement that the seller is a VAT-registered person, followed by his TIN; (2) The total amount which the purchaser pays or is obligated to pay to the seller with the indication that such amount includes the VAT; Provided , That: xxx xxx xxx (c) If the sale is subject to zero percent (0%) VAT, the term 'zero-rated sale' shall be written or printed prominently on the invoice or receipt; x x x" Upon further evaluation, the Court finds that the reported zero-rated sales in the amount of P17,255,348.43 could not qualify for VAT zero-rating for petitioner's failure to comply with the invoicing requirements under the NIRC of 1997, as amended, and RR No. 16-2005, as follows: OR/SI OR/SI Date Customer Amount Exhibit 1) Sale of services not supported by VAT OR 1st Quarter CR 0033 1/11/16 TAGANITO HPAL NICKEL CORPORATION P615,887.20 P-337, P-4829 Subtotal 1st Quarter 615,887.20 Total Sale of service not supported by VAT OR 615,887.20 2) Sale of services supported by VAT OR wherein date, payor details or amounts are unreadable 1st Quarter OR 1010 1/15/16 TAGANITO HPAL NICKEL CORPORATION 1,948,286.07 P-4796 SI 1094/SI 1093/SI 1092 2/20/16 TAGANITO HPAL NICKEL CORPORATION 4,976,751.35 P-134 to P-134-B Subtotal 1st Quarter 6,925,037.42 2nd Quarter SI 1157 5/6/16 TAGANITO HPAL NICKEL CORPORATION 2,846,064.78 P-338 Subtotal 2nd Quarter 2,846,064.78 4th Quarter OR 1051 12/16/16 TAGANITO HPAL NICKEL CORPORATION 516,274.00 P-4827 OR 1051 12/16/16 TAGANITO HPAL NICKEL CORPORATION 2,808,076.00 P-4827 OR 1051 12/16/16 TAGANITO HPAL NICKEL CORPORATION 1,744,010.03 P-4827 OR 1051 12/16/16 TAGANITO HPAL NICKEL CORPORATION 1,800,000.00 P-4827 Subtotal 4th Quarter 6,868,360.03 Total Sale of services supported by VAT OR wherein date, payor details or amounts are unreadable 16,639,462.23 Total Zero-rated Sales Not Properly Substantiated P17,255,349.43 Thus, the total disallowances on petitioner's reported total zero-rated sales per the Court's verification amounts P20,564,368.63, as shown hereunder: cDHAES Disallowances 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total Sale of services to non-resident foreign client not qualified for VAT zero-rating under Sec. 108 (B) (2) of the NIRC of 1997, as amended - - P1,023,663.08 P2,285,356.12 P3,309,019.20 Sale of service not supported by VAT OR P615,887.20 - - - 615,887.20 Sale of goods supported by VAT ORs but with unreadable details (date, payor details, or amount) 6,925,037.42 2,846,064.78 - 6,868,360.03 16,639,462.23 Total Disallowed Zero-rated Sales P7,540,924.62 P2,846,064.78 P1,023,663.08 P9,153,716.15 P20,564,368.63 In addition, the Court finds that the following amounts of zero-rated sales reported by petitioner were higher than the amounts reflected in the VAT invoices and official receipts, thus, the difference of P164,330.79 should likewise be disallowed: SI/OR SI/OR Date Customer Name Per SLS Per VAT Invoice/Official Receipt Variance Exhibit 1st Quarter SI 1072 1/29/16 CORAL BAY NICKEL CORPORATION P44,625.46 P44,625.28 P0.18 P-101 SI 1095 2/22/16 CORAL BAY NICKEL CORPORATION 30,049.07 30,049.04 0.03 P-124 Subtotal 1st Quarter P74,674.53 P74,674.32 P0.21 2nd Quarter OR 1016 4/1/16 CORAL BAY NICKEL CORPORATION P1,535,533.74 P1,535,533.73 0.01 P-4800 SI 1181 5/31/16 CORAL BAY NICKEL CORPORATION 46,788.32 46,788.00 0.32 P-166 Subtotal 2nd Quarter P1,582,322.06 P1,582,321.73 0.33 3rd Quarter OR 1030 8/12/16 TAGANITO HPAL NICKEL CORPORATION P1,816,513.19 P-4811 OR 1030 8/12/16 TAGANITO HPAL NICKEL CORPORATION 2,500,000.00 P4,155,182.94 P161,330.25 P-4811 OR 1031 8/28/16 TAGANITO HPAL NICKEL CORPORATION 60,000.00 57,000.00 3,000.00 P-4812 Subtotal 3rd Quarter P4,376,513.19 P4,212,182.94 P164,330.25 Total Excess Zero-rated Sale Claimed P164,330.79 In sum, out of the total reported zero-rated sales of P83,178,005.10, only the amount of P62,449,305.68 shall be considered as valid zero-rated sales for the four quarters of TY 2016, detailed as follows: 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total Zero-rated Sales P22,759,452.94 P19,064,944.08 P20,776,007.25 P20,577,600.83 P83,178,005.10 Less: Disallowances 7,540,924.62 2,846,064.78 1,023,663.08 9,153,716.15 20,564,368.63 Excess Claims 0.21 0.33 164,330.25 - 164,330.79 Total Valid Zero-rated Sales P15,218,528.11 P16,218,878.97 P19,588,013.92 P11,423,884.68 P62,449,305.68 Fourth and Fifth Requisites: Petitioner incurred/paid input taxes attributable to zero-rated sales in the total amount of P291,262.93 Having found that petitioner had valid VAT zero-rated sales in the total amount of P62,449,305.68 for the four quarters of TY 2016, the Court shall determine whether petitioner complied with the requisites pertaining to the input VAT being claimed for refund or issuance of a tax credit certificate. For the four quarters of TY 2016, petitioner claims a total amount of P6,762,558.04 allowable input VAT arising from its domestic purchases and importation of goods other than capital goods, and domestic purchases of services. Summarized below are petitioner's current domestic purchases and importation of goods other than capital goods and domestic purchases of services in the total amount of P56,354,650.42, and the corresponding input taxes for the four quarters of TY 2016 in the total amount of P6,762,558.04: ASEcHI Gross Amount of Purchases and Importations 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total Domestic Purchases of Goods Other Capital Goods (Line 21E) P114,574.85 P98,156.47 P87,326.02 P287,282.26 P587,339.60 Importation of Goods Other than Capital Goods (Line 21G) 759,331.16 1,323,256.87 395,878.16 946,617.16 3,425,083.55 Domestic Purchase of Services (Line 21I) 318,512.62 484,343.63 892,450.48 1,497,611.51 3,192,918.24 Others (Line 21N) 9,965,604.54 15,473,118.03 6,709,880.34 17,000,706.32 49,149,309.23 Total Current Purchases/Importations P11,158,023.17 P17,378,875.00 P8,085,535.00 P19,732,217.25 P56,354,650.42 Input Tax on Purchases and Importations 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total Domestic Purchases of Goods Other Capital Goods (Line 21F) P13,748.98 P11,778.78 P10,479.12 P34,473.87 P70,480.75 Importation of Goods Other than Capital Goods (Line 21H) 91,119.74 158,790.82 47,505.38 113,594.06 411,010.00 Domestic Purchase of Services (Line 21J) 38,221.51 58,121.24 107,094.06 179,713.38 383,150.19 Others (Line 21O) 42 1,195,872.54 1,856,774.16 805,185.64 2,040,084.76 5,897,917.10 Total Current Input Tax P1,338,962.77 P2,085,465.00 P970,264.20 P2,367,866.07 P6,762,558.04 Petitioner claims that out of the total domestic purchases and importation of goods other than capital goods, and domestic purchases of services in the total amount of P56,354,650.42, with corresponding input VAT in the amount of P6,762,558.04, domestic purchases and importations as reflected in "Others (Line 21N/O)" of the Quarterly VAT Returns of TY 2016 in the total amount of P49,149,309.23, with corresponding input VAT amount of P5,897,917.10 should be granted for refund. As validated by the Court-commissioned Independent Certified Public Accountant (ICPA) in the Amended ICPA Report, 43 petitioner segregated the purchases of goods and services and importations directly attributable and allocable to zero-rated sales in the portion "Others (Line 21N/O)" in the Quarterly VAT Returns of TY 2016. Domestic purchases and importation of goods other than capital goods, and domestic purchase of services in the total amount of P49,149,309.23, with corresponding input VAT of P5,897,917.10 as reported in "Others (Line 21N/O)" in the Quarterly VAT Returns of TY 2016 was determined by petitioner 44 and the ICPA 45 to be composed of purchases of goods and services directly attributable to zero-rated sales, and purchases of goods and services allocable to zero-rated sales, as follows: 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total Purchases allocated to Zero-rated Sales P9,592,319.46 P15,168,639.11 P6,215,096.42 P16,523,644.49 P47,499,699.48 Purchases Directly Attributable to Zero-rated Sales 373,285.08 304,478.92 494,783.92 477,061.83 1,649,609.75 Total Purchases Allocated and Directly Attributable to Zero-rated Sales (Line 21N of Quarterly VAT Return) P9,965,604.54 P15,473,118.03 P6,709,880.34 P17,000,706.32 P49,149,309.23 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total Input VAT allocated to Zero-rated Sales P1,151,078.34 P1,820,236.69 P745,811.57 P1,982,837.34 P5,699,963.94 Input VAT Directly Attributable to Zero-rated Sales 44,794.21 36,537.47 59,374.07 57,247.42 197,953.17 Total Input VAT Allocated and Directly Attributable to Zero-rated Sales P1,195,872.54 P1,856,774.16 P805,185.64 P2,040,084.76 P5,897,917.11 Upon verification by the Court, it is found that petitioner failed to prove that certain domestic purchases and importation of goods other than capital goods, and domestic purchase of services in the total amount of P1,649,609.75 were directly attributable to zero-rated sales made during the four quarters of TY 2016. Thus, the Court is constrained to consider the whole amount of P56,354,650.42 as petitioner's total domestic purchases and importation of goods other than capital goods, and domestic purchase of services, subject to proportional allocation between VATable, VAT-exempt and VAT zero-rated sales pursuant to Section 112 (A) of the NIRC of 1997, as amended. cTDaEH Of the total amount of P56,354,650.42 subject to allocation, the ICPA was only able to vouch domestic purchases and importation of goods other than capital goods, and domestic purchases of services in the total amount of P51,947,439.73, as shown below: 46 Domestic Purchases P22,189,548.08 Importations 29,757,891.65 Total Vouched Purchases and Importations P51,947,439.73 Add: Unaccounted Purchases 4,407,210.69 Total Reported Domestic Purchases and Importations P56,354,650.42 Therefore, the unaccounted purchases amounting to P4,407,210.69, which were not supported with VAT official receipts or invoices, shall not be considered in the computation of petitioner's valid input taxes for the period for failure to substantiate the same. The input tax arising from said unsubstantiated purchases amounting to P528,865.28 shall thus be disallowed. 47 Of the total vouched purchases and importations made by petitioner in the amount of P51,947,439.73, the amount of P6,318,520.73 arising from domestic purchases of goods other than capital goods and domestic purchase of services were not properly substantiated, and which shall be disallowed by the Court for failure to meet the invoicing requirements under Sections 110 (A), 113 (A) and (B), and 237 of the NIRC of 1997, as amended, in relation to Sections 4.110-1, 4.110-2, 4.110-8, and 4.113-1 of RR No. 16-05, as amended. Thus, per the ICPA Report, the total domestic purchases and importation of goods other than capital goods, and domestic purchase of services which were validly substantiated amounted to P45,628,919.00, as follows: 48 Domestic Purchases P15,871,027.35 Importations 29,757,891.65 Total Substantiated Domestic Purchases and Importations P45,628,919.00 Finding the exceptions noted by the ICPA reasonable and appropriate, the Court shall further disallow input VAT in the total amount of P758,196.27 sourced from domestic purchases and importation of goods other than capital goods, and domestic purchase of services which failed to follow the invoicing requirements required by law and regulations, detailed as follows: 49 Period Input VAT per ICPA Findings Not Substantiated Substantiated Total 1st Quarter P177,327.57 P164,440.38 P341,767.95 2nd Quarter 150,499.55 280,240.64 430,740.19 3rd Quarter 189,997.23 411,800.52 601,797.75 4th Quarter 79,414.02 1,048,041.65 1,127,455.67 Out of Period 160,957.90 - 160,957.90 Total P758,196.27 P1,904,523.19 P2,662,719.46 Moreover, upon further verification, the Court shall disallow the following input VAT on domestic purchases of goods other than capital goods, and domestic purchases of services, in the total amount of P1,562,076.91, for failure to comply with invoicing requirements: cSaATC Date Exhibit No. Payee Amount 1) Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where amount of VATable sale is not presented or incorrectly presented 1st Quarter 3/8/2016 P-370 GERRY'S GRILL P249.75 1/22/2016 P-1452 CLYBROS MERCHANDISING, INC. 342.27 1/29/2016 P-1681 PARKWAY 105.71 2/20/2016 P-1692 SAINT PETER DIAGNOSTIC AND LABORATORY 85.71 2/20/2016 P-1756 SAINT PETER DIAGNOSTIC AND LABORATORY 85.71 3/11/2016 P-2454 MOTHERS CHOICE SURIGAO, INC. 304.71 3/4/2016 P-2468 PRUDENTIAL CUSTOMS BROKERAGE SERVICES, INC. 516.11 3/18/2016 P-3917 PRESAM SHELL SERVICE CENTER 99.49 Subtotal 1st Quarter 1,689.97 2nd Quarter 5/23/2016 P-2329 SIMPLEX INDUSTRIAL CORPORATION 85.29 Subtotal 2nd Quarter 85.29 3rd Quarter 7/23/2016 P-1969 ULING ROASTERS 77.14 7/12/2016 P-1975 ULING ROASTERS 57.86 7/15/2016 P-1986 ULING ROASTERS 77.14 7/8/2016 P-2003 RIVERSIDE PARTS MASTER, INC. 120.54 7/11/2016 P-2018 K3CP CORPORATION 74.89 7/1/2016 P-2024 ULING ROASTERS 77.14 7/8/2016 P-2043 ULING ROASTERS 77.14 7/8/2016 P-2047 PARKWAY 16.56 9/29/2016 P-2628 LAVENDER SHELL SERVICE STATION AND GEN. MERCHANDISE 18 9/27/2016 P-2657 BOUNTY AGRO VENTURES, INC. 158.57 8/7/2016 P-3018 N & J HYDRAULIC HOSE INDUSTRIAL & HEAVY PARTS 77.14 8/9/2016 P-3726 JCN COPY & PRINTSHOP 37.5 Subtotal 3rd Quarter 869.62 4th Quarter 11/4/2016 P-1510 PINKY YU 214.29 10/14/2016 P-1535 AKROASIA PETRON SERVICE STATION 107.14 12/20/2016 P-1864 DY TEBAN HARDWARE AND AUTO SUPPLY 96.43 11/15/2016 P-4251 BALIWAG LECHON MANOK, INC. 41.79 10/7/2016 P-4370 STAREV MOTORIST SERVICE CENTER 10.71 Subtotal 4th Quarter 470.36 Total Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where amount of VATable sale is not presented P3,115.24 2) Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR wherein the VAT amount is not separately/properly indicated 1st Quarter 2/15/2016 P-1131 CEBU GAZLAND ENTERPRISES P64.61 2/20/2016 P-1160 ROCO'S LECHON 321.43 1/22/2016 P-1238 COMTECH REFRIGERATION AND AIRCONDITIONING SERVICES 2,785.71 2/8/2016 P-1587 IRON CITY CALTEX STATION 101.79 2/19/2016 P-1744 COKALIONG SHIPPING LINES, INC. 56.25 3/3/2016 P-3409 ESPRUTINGKLE GAS & SERVICE, INC. 11.25 Subtotal 1st Quarter 3,341.04 2nd Quarter 5/20/2016 P-649 GAC PHILIPPINES, INC. 41,896.80 5/20/2016 P-651 GAC PHILIPPINES, INC. 2,185.39 6/9/2016 P-1031 JETT CONSTRUCTION AND ELECTRICAL SUPPLY 11.25 4/14/2016 P-2803 MANDAUE TRADE ENTER CEBU 3.75 5/11/2016 P-3569 KIMLY MERCHANDISE 42.86 Subtotal 2nd Quarter 44,140.05 3rd Quarter 7/8/2016 P-671 GAC PHILIPPINES, INC. 2,383.23 8/12/2016 P-673 GAC PHILIPPINES, INC. 4,644.71 8/26/2016 P-766 JETT CONSTRUCTION AND ELECTRICAL SUPPLY 53.57 9/24/2016 P-2669 HONEYLEMON FOODS, INC. 12.11 Subtotal 3rd Quarter 7,093.62 4th Quarter 10/21/2016 P-612 TRIPLEPLAYHUB NETWORKS, INC. 15,284.57 Subtotal 4th Quarter 15,284.57 Total Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR wherein the VAT amount is not separately/properly indicated P69,859.28 3) Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR wherein indicated TIN is incorrect, incomplete or unreadable 4th Quarter 10/7/2016 P-748 GLOBAL SECURITY SOLUTIONS, INC. P536.8 11/18/2016 P-1781 CITI HARDWARE BACOLOD, INC. 149.08 Subtotal 4th Quarter 685.88 Total Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR wherein indicated TIN is incorrect, incomplete or unreadable P685.88 4) Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where the payor's name is incorrect, incomplete, or unreadable 1st Quarter 1/21/2016 P-744 RICHMONDE PLAZA CONDOMINIUM ASSOCIATION, INC. P766.8 2/19/2016 P-661 GAC PHILIPPINES, INC. 1,356.26 2/2/2016 P-1073 GOODHOPE HARDWARE 38.04 2/5/2016 P-1086 GOODHOPE HARDWARE 19.29 2/8/2016 P-1096 ESPRUTINKLE GAS & SERVICES, INC. 562.5 2/11/2016 P-1116 GOODHOPE HARDWARE 19.07 2/11/2016 P-1117 CEBU TRADECENTER, INC. 35.25 2/12/2016 P-1126 GOODHOPE HARDWARE 306.43 2/13/2016 P-1127 ESPRUTINGKLE GAS & SERVICES, INC. 10.71 2/20/2016 P-1162 GOODHOPE HARDWARE 11.57 2/19/2016 P-1174 GOODHOPE HARDWARE 205.93 2/22/2016 P-1175 GOODHOPE HARDWARE 8.84 1/6/2016 P-1206 ESPRUTINGKLE GAS AND SERVICE, INC. 174.89 2/27/2016 P-1738 PHILIPPINE PORTS AUTHORITY 2.37 3/21/2016 P-2389 LAVENDER SHELL SERVICE STATION & GEN MDSE. 139.24 3/22/2016 P-3352 K-BROTHERS LAYOUT & PRINT 37.5 2/24/2016 P-3437 DMC BUSA PRINTERS 514.29 2/26/2016 P-3450 GOODHOPE HARDWARE 192.86 2/28/2016 P-3458 ABACUS BOOK AND CARD CORP. 12.86 Subtotal 1st Quarter 4,414.70 2nd Quarter 6/27/2016 P-901 SANFORD MARKETING CORPORATION 121.71 6/27/2016 P-906 ABACUS BOOK AND CARD CORP. 12.86 6/28/2016 P-909 ESPRUTINGKLE GAS & SERVICE, INC. 1,101.23 6/30/2016 P-915 PHILIPPINES, INC. 267.86 6/20/2016 P-985 STK ELECTRONICS 1.61 5/30/2016 P-1033 CEBU TRADE CENTER, INC. 3 6/14/2016 P-2510 D MICHAEL CO. INDUSTRIAL SUPPLY CORP. 160.71 6/14/2016 P-2592 LAVENDER SHELL SERVICE STATION & GEN MDSE. 191.81 6/7/2016 P-2612 HIRAM ENTERPRISES 241.71 6/24/2016 P-3553 PETRON 53.57 6/13/2016 P-3659 MAYAD LIFE OIL CORPORATION 107.14 Subtotal 2nd Quarter 2,263.21 3rd Quarter 8/27/2016 P-762 NEW VENTURES SHELL STATION 9.41 8/19/2016 P-801 ESPRUTINGKLE GAS & SERVICE, INC. 1,022.14 8/1/2016 P-817 ESPRUTINGKLE GAS & SERVICE, INC. 235.29 8/3/2016 P-825 PHILIPPINES, INC. 267.86 8/11/2016 P-832 SANFORD MARKETING CORPORATION 76.66 7/18/2016 P-862 PYEZA PARTS DEPOT, INC. 10.71 7/20/2016 P-864 GOODHOPE HARDWARE 8.57 7/11/2016 P-902 SANFORD MARKETING CORPORATION 43.37 7/29/2016 P-1924 B2Y'S AUTO SUPPLY AND GENERAL MERCHANDISE 217.5 7/29/2016 P-1925 IRON CITY CALTEX STATION 261.96 7/29/2016 P-1943 TT & COMPANY, INC. 1,267.26 7/15/2016 P-1985 TT & COMPANY, INC. 1,091.24 7/1/2016 P-1993 CD-R KING GEN. MERCHANDISE 6.43 7/8/2016 P-2009 HIRAM ENTERPRISES 192.86 7/10/2016 P-2016 HONEYLEMON FOODS, INC. 10.61 7/1/2016 P-2029 JOLLIBEE 16.07 7/8/2016 P-2049 PARKWAY 263.57 9/19/2076 P-2679 ULING ROASTERS 138.75 9/20/2016 P-2683 PIGAR TRADING 539.89 8/23/2016 P-2963 CLAVER GENERAL MERCHANDISE 24 8/12/2016 P-2987 TT & COMPANY, INC. 1,109.24 8/7/2016 P-2994 IRON CITY GROCERY 81.64 8/8/2016 P-3017 B2Y'S AUTO SUPPLY AND GENERAL MERCHANDISE 6.96 8/6/2016 P-3019 TRI-MIX ENTERPRISES 5.14 7/4/2016 P-3051 GRANDIOSA CORPORATION 110.25 9/2/2016 P-3180 NG KHAI DEVELOPMENT CORPORATION 246.43 9/7/2016 P-3196 ESPRUTINGKLE GAS & SERVICES, INC. 1,863.00 9/8/2016 P-3200 AEROPHONE ENTERPRISES & CO. 160.71 9/22/2016 P-3230 MANDAUE STAR OIL GAS & CONVENIENCE STORE 65.79 8/16/2016 P-3742 SUPERVALUE, INC. 22.45 7/21/2016 P-3829 SUPERVALUE, INC. 14.97 Subtotal 3rd Quarter 9,390.73 4th Quarter 10/10/2016 P-1524 D.Y.M TRADING GENERAL MERCHANDISE 64.3 10/15/2016 P-1539 REPHIL BASAK, INC. 21.43 10/16/2016 P-1540 ESPRUTINGKLE GAS & SERVICE, INC. 186.42 10/20/2016 P-1553 ESPRUTINGKLE GAS & SERVICE, INC. 1,222.71 10/21/2016 P-1554 CHERRY ROSE BUILDERS & CONSTRUCTION SUPPLY 69.64 10/6/2016 P-1569 MAPECON PHILIPPINES, INC. 267.86 12/20/2016 P-1863 PATTYS BAKESHOP 21.43 10/16/2016 P-2113 CEBU HOME & BUILDERS CENTRE 203.81 10/3/2016 P-2182 IRON CITY CALTEX STATION 90 10/28/2016 P-3158 JAY C DESIGNS, INC. 99.11 10/28/2016 P-3159 NEW SEAMAN TRADE MARKETING COMMERCIAL, INC. 150 12/8/2016 P-4290 SML HABITAT CORPORATION 257.14 12/10/2016 P-4296 SML HABITAT CORPORATION 385.71 11/7/2016 P-4464 DHL EXPRESSCORP. 138.32 Subtotal 4th Quarter 3,177.88 Total Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where the payor's name is incorrect, incomplete, or unreadable P19,246.52 5) Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where the business address is incorrect, incomplete, or unreadable 1st Quarter 3/17/2016 P-395 THE BELLEVUE MANILA P1,640.79 2/16/2016 P-434 CITRA METRO MANILA TOLLWAYS CORPORATION 107.14 3/5/2016 P-492 AEROPHONE ENTERPRISES AND CO. 107.14 2/19/2016 P-502 AEROPHONE ENTERPRISES AND CO. 107.14 1/26/2016 P-1761 GLOBAL SECURITY SOLUTIONS, INC. 341.51 2/19/2016 P-659 GAC PHILIPPINES, INC. 1,882.96 2/19/2016 P-665 GAC PHILIPPINES, INC. 1,842.06 2/19/2016 P-667 GAC PHILIPPINES, INC. 1,897.56 2/2/2016 P-1076 GRANDRESTO, INC. 629.21 2/3/2016 P-1078 CEBU ATLANTIC HARDWARE 629.46 2/4/2016 P-1083 DMC BUSA PRINTERS 535.71 2/9/2016 P-1097 NATIONAL BOOK STORE 117.38 2/9/2016 P-1100 PACIFIC CATV, INC. 133.93 2/10/2016 P-1115 CEBU ATLANTIC HARDWARE 911.63 2/15/2016 P-1129 CAV AUTO OPTIONS, INC. 162.51 2/15/2016 P-1133 GOODHOPE HARDWARE 564.27 2/16/2016 P-1135 LANTAW SEAFOOD & GRILL, INC. 251.25 2/23/2016 P-1177 SUPER SHOPPING MARKET, INC. 557.14 2/19/2016 P-1178 MACRO TIRES, INC. 895.71 1/9/2016 P-1182 GOODHOPE HARDWARE 310.4 1/13/2016 P-1185 GOODHOPE HARDWARE 116.58 1/14/2016 P-1199 SANFORD MARKETING CORPORATION 115.15 1/13/2016 P-1200 GOODHOPE HARDWARE 107.15 1/14/2016 P-1211 ESPRUTINGKLE GAS AND SERVICE, INC. 161.96 1/15/2016 P-1216 JV SHOP N SHOP CO. 107.14 1/12/2016 P-1223 PACIFIC CATV, INC. 133.82 1/20/2016 P-1230 PACIFIC CATV, INC. 214.71 1/25/2016 P-1245 GOODHOPE HARDWARE 217.82 1/28/2016 P-1251 GOODHOPE HARDWARE 139.23 1/26/2016 P-1253 GOODHOPE HARDWARE 121.5 2/1/2016 P-1263 I.C.E.D. PETRON SERVICE STATION 149.97 1/7/2016 P-1370 PARKWAY 132.79 1/16/2016 P-1375 SURIGAO M. S. ENTERPRISES 482.14 1/17/2016 P-1382 IRON CITY CALTEX STATION 107.14 1/19/2016 P-1386 B2YS AUTO SUPPLY AND GENERAL MERCHANDISE 530.89 1/19/2016 P-1389 IRON CITY CALTEX STATION 107.14 1/9/2016 P-1392 CEBU BELMONT, INC. 302.68 1/9/2016 P-1394 THINKING TOOLS, INCORPORATED 757.5 1/14/2016 P-1405 IRON CITY CALTEX STATION 107.14 1/22/2016 P-1415 TRIMIX ENTERPRISES 109.28 1/25/2016 P-1431 IRON CITY CALTEX STATION 107.14 1/29/2016 P-1433 NEW MINDANAO HARDWARE AND AUTO PARTS SUPPLIES 252.86 1/29/2016 P-1434 HONEYLEMON FOODS, INC. 116.78 1/22/2016 P-1453 MOTHERS CHOICE SURIGAO, INC. 172.45 2/1/2016 P-1570 IRON CITY CALTEX STATION 107.14 2/1/2016 P-1571 MOTHERS CHOICE SURIGAO, INC. 165.64 2/3/2016 P-1573 MOTHERS CHOICE SURIGAO, INC. 525.53 2/3/2016 P-1572 MOTHERS CHOICE SURIGAO, INC. 166.07 2/3/2016 P-1575 IRON CITY CALTEX STATION 107.14 2/9/2016 P-1590 IRON CITY CALTEX STATION 107.14 2/12/2016 P-1593 IRON CITY CALTEX STATION 107.14 2/12/2016 P-1595 MOTHERS CHOICE SURIGAO, INC. 123.42 2/13/2016 P-1602 SAINT PETER DIAGNOSTIC AND LABORATORY 1,425.54 2/14/2016 P-1625 IRON CITY CALTEX STATION 107.14 2/17/2016 P-1654 CARTECH ENTERPRISE 567.86 2/18/2016 P-1657 IRON CITY CALTEX STATION 107.14 2/18/2016 P-1658 TT & COMPANY, INC. 192.21 2/18/2016 P-1660 WINSHER MARKETING 685.18 1/29/2016 P-1678 MOTHERS CHOICE SURIGAO, INC. 343.61 2/21/2016 P-1695 EMB NATURAL GAS STATION 139.29 2/22/2016 P-1701 IRON CITY CALTEX STATION 211.71 2/26/2016 P-1706 SURIGAO M.S. ENTERPRISE 482.14 2/26/2016 P-1707 D MICHAEL CO. INDUSTRIAL SUPPLY CORP. 241.07 2/18/2016 P-1709 TT & COMPANY, INC. 1,653.78 2/18/2016 P-1712 MOTHERS CHOICE SURIGAO, INC. 1,320.91 2/18/2016 P-1714 TAI-PAN DEVELOPMENT, INC. 133.62 2/18/2016 P-1715 MOTHERS CHOICE SURIGAO, INC. 138.64 2/24/2016 P-1722 ULING ROASTERS 115.71 2/26/2016 P-1727 TT & COMPANY, INC. 937.92 2/26/2016 P-1728 MOTHERS CHOICE SURIGAO, INC. 235.52 3/23/2016 P-2374 MOTHERS CHOICE SURIGAO, INC. 330.6 3/23/2016 P-2377 TT & COMPANY, INC. 918.01 3/23/2016 P-2380 TT & COMPANY, INC. 369.64 3/31/2016 P-2382 TT & COMPANY, INC. 939.62 3/31/2016 P-2385 MOTHERS CHOICE SURIGAO, INC. 263.2 3/31/2016 P-2387 TAI-PAN DEVELOPMENT, INC. 162.71 3/26/2016 P-2391 IRON CITY CALTEX STATION 116.98 3/28/2016 P-2392 IRON CITY CALTEX STATION 107.14 3/18/2016 P-2396 TT & COMPANY, INC. 1,040.07 3/18/2016 P-2397 MOTHERS CHOICE SURIGAO, INC. 615.5 3/18/2016 P-2401 PARKWAY 883.44 3/8/2016 P-2416 TT & COMPANY, INC. 641.25 3/18/2016 P-2419 SILICON VALLEY 861.43 3/11/2016 P-2450 MOTHERS CHOICE SURIGAO, INC. 833.67 3/4/2016 P-2485 TAI-PAN DEVELOPMENT, INC. 105.14 3/31/2016 P-3323 ESPRUTINGKLE GAS & SERVICE, INC. 187.5 3/30/2016 P-3364 PACIFIC CATV, INC. 133.93 3/19/2016 P-3372 K-BROTHERS LAYOUT & PRINT 112.5 3/23/2016 P-3375 K AND S HOTEL & MANAGEMENT CORPORATION 176.79 3/22/2016 P-3376 K AND S HOTEL & MANAGEMENT CORPORATION 353.57 3/8/2016 P-3385 GOODHOPE HARDWARE 795.86 3/9/2016 P-3388 SUPER SHOPPING MARKET, INC. 209.33 3/10/2016 P-3390 AEROPHONE ENTERPRISES & CO. 107.14 3/1/2016 P-3408 GOODHOPE HARDWARE 409.39 3/7/2016 P-3422 ESPRUTINGKLE GAS & SERVICE, INC. 865.93 3/7/2016 P-3430 ACE HARDWARE PHILIPPINES, INC. 374.87 Subtotal 1st Quarter 40,859.28 2nd Quarter 6/19/2016 P-364 TRAVELBEE MANAGEMENT CORPORATION 324 6/24/2016 P-365 TRAVELBEE MANAGEMENT CORPORATION 1,259.14 5/22/2016 P-390 THE BELLEVUE MANILA 4,107.21 4/17/2016 P-392 THE BELLEVUE MANILA 1,302.63 6/3/2016 P-420 PETRON XPRESSFILLSTATION 123.82 4/1/2016 P-428 PETRON XPRESSFILLSTATION 123.07 4/1/2016 P-429 PETRON XPRESSFILLSTATION 119.37 4/1/2016 P-430 CITRA METRO MANILA TOLLWAYS CORPORATION 214.29 4/13/2016 P-4787 GLOBAL SECURITY SOLUTIONS, INC. 308.53 4/13/2016 P-4789 GLOBAL SECURITY SOLUTIONS, INC. 668.85 6/22/2016 P-587 PEAR ENTERPRISES 35,235.00 5/27/2016 P-2852 MOTHERS CHOICE SURIGAO, INC. 309.65 5/27/2016 P-2854 MOTHERS CHOICE SURIGAO, INC. 118.34 5/27/2016 P-2857 PARKWAY 139.88 5/22/2016 P-2861 IRON CITY CALTEX STATION 107.14 5/24/2016 P-2864 IRON CITY CALTEX STATION 107.14 5/26/2016 P-2867 GARDENSTATE ENTERPRISES, INC. 179.79 5/26/2016 P-2869 TOYOTA BUTUAN CITY 136.6 5/20/2016 P-2882 PARKWAY 222.79 5/20/2016 P-2883 MOTHERS CHOICE SURIGAO, INC. 307.53 5/20/2016 P-2885 MOTHERS CHOICE SURIGAO, INC. 106.34 5/20/2016 P-2886 MOTHERS CHOICE SURIGAO, INC. 318.98 4/16/2016 P-3058 IRON CITY CALTEX STATION 107.14 4/9/2016 P-3061 IRON CITY CALTEX STATION 107.14 4/18/2016 P-3062 IRON CITY CALTEX STATION 858.75 4/22/2016 P-3071 IRON CITY CALTEX STATION 107.14 4/25/2016 P-3073 IRON CITY CALTEX STATION 107.14 4/28/2016 P-3076 IRON CITY CALTEX STATION 107.14 4/23/2016 P-3078 SAINT PETER DIAGNOSTIC AND LABORATORY 273.21 4/14/2016 P-3094 IRON CITY CALTEX STATION 113.12 4/22/2016 P-3104 TT AND COMPANY, INC. 731.44 4/30/2016 P-3112 TT AND COMPANY, INC. 960.95 4/30/2016 P-3116 MOTHERS CHOICE SURIGAO, INC. 131.44 4/9/2016 P-3125 TT AND COMPANY, INC. 800.54 4/9/2016 P-3126 CLYBROS MERCHANDISING, INC. 165.12 4/9/2016 P-3129 MOTHERS CHOICE SURIGAO, INC. 342.43 4/14/2016 P-3133 MOTHERS CHOICE SURIGAO, INC. 293.43 4/14/2016 P-3135 TT AND COMPANY, INC. 891.89 4/14/2016 P-3136 CLYBROS MERCHANDISING, INC. 120.35 4/5/2016 P-3141 NEW SURIGAO PAINTHAUS AND AUTOPARTS GEN. MERCHANDISE 107.15 4/4/2016 P-3327 COMTECH REFRIGERATION & AIRCONDITIONING SERVICES 401.79 4/4/2016 P-3328 OCTAGON COMPUTER SUPERSTORE 266.14 6/10/2016 P-4401 GAC PHILIPPINES, INC. 4,835.19 Subtotal 2nd Quarter 57,668.73 3rd Quarter 8/30/2016 P-404 EJS GARDEN BY THE BAY 380.36 8/10/2016 P-410 PETRON XPRESSFILLSTATION 126.22 8/13/2016 P-411 BATTERY MASTER'S, INC. 616.07 9/15/2016 P-571 LINCOLN REALTY CORP. 3,214.29 8/20/2016 P-755 PRIVIS CORPORATION 130.18 8/24/2016 P-758 SANFORD MARKETING CORPORATION 165.72 9/16/2016 P-2694 375 CAR SPECIALIST 2,294.89 9/24/2016 P-3232 OCTAGON COMPUTER SUPERSTORE 425.89 9/26/2016 P-3240 PACIFIC CATV, INC. 142.5 7/1/2016 P-4136 CEBGO, INC. 107.14 9/26/2016 P-4334 FRESH N FAMOUS FOODS, INC. 17.44 Subtotal 3rd Quarter 7,620.40 4th Quarter 11/26/2016 P-361 TRAVELBEE MANAGEMENT CORPORATION 360 11/26/2016 P-362 TRAVELBEE MANAGEMENT CORPORATION 1,080.00 11/27/2016 P-363 TRAVELBEE MANAGEMENT CORPORATION 180 12/5/2016 P-448 GRANDESTO, INC. 599.25 12/5/2016 P-449 GRANDESTO, INC. 85.61 10/13/2016 P-462 UY AND DE GUZMAN LAW OFFICES 4,800.00 12/20/2016 P-746 GLOBAL SECURITY SOLUTIONS, INC. 536.8 10/18/2016 P-575 PEAR ENTERPRISES 141,360.00 12/21/2016 P-579 PEAR ENTERPRISES 214,800.00 11/17/2016 P-580 PEAR ENTERPRISES 195,300.00 11/7/2016 P-581 PEAR ENTERPRISES 80,212.50 11/22/2016 P-1460 FRONTLAKE, INC. 184.18 11/22/2016 P-1462 SANFORD MARKETING CORPORATION 195.59 11/23/2016 P-1467 ROBINSONS SUPERMARKET CORPORATION 140.99 11/23/2016 P-1468 ROBINSONS SUPERMARKET CORPORATION 119.14 11/23/2016 P-1469 ROBINSONS SUPERMARKET CORPORATION 230.36 11/26/2016 P-1477 ESPRUTINGKLE GAS AND SERVICE, INC. 2,241.00 11/16/2016 P-1495 SANFORD MARKETING CORPORATION 212.97 11/18/2016 P-1498 ALAIN ASIA TRADING CORPORATION 169.29 11/19/2016 P-1499 ESPRUTINGKLE GAS AND SERVICE, INC. 214.29 11/19/2016 P-1500 ROBINSONS, INCORPORATED 133.1 11/5/2016 P-1512 GOLDEN COWRIE HUKAD NATIVE RESTAURANT 147.21 11/5/2016 P-1513 ESPRUTINGKLE GAS AND SERVICE, INC. 2,317.50 10/7/2016 P-1522 GRANDRESTO, INC. 428.04 10/13/2016 P-1525 SANFORD MARKETING CORP. 158.38 10/15/2016 P-1538 NISSAN CEBU DISTRIBUTORS, INC. 1,555.29 10/18/2016 P-1547 ACE HARDWARE PHILIPPINES, INC. 819.4 12/28/2016 P-1847 DY TEBAN HARDWARE AND AUTO SUPPLY 167.14 12/18/2016 P-1860 HUKAD BUTUAN 130.61 11/4/2016 P-2232 SURIGAONON VISAYAN MARKETING CORPORATION 155.36 11/11/2016 P-2239 SURIGAONON VISAYAN MARKETING CORPORATION 155.36 10/26/2016 P-3155 PACIFIC CATV, INC. 142.5 10/27/2016 P-3156 FAMILYHEALTH AND BEAUTY CORP. 135.59 12/8/2016 P-3280 CHOOBI CHOOBI FLAVORS CORPORATION 108.64 12/14/2016 P-3292 GOLDEN COWRIE HUKAD NATIVE RESTAURANT 201.75 11/30/2016 P-3300 PARILYA SOUTH SEAFOOD AND GRILL 154.82 11/14/2016 P-4236 SUPERVALUE, INC. 106.55 11/18/2016 P-4243 MAGALLANES MANAGEMENT CORPORATION 201.8 12/10/2016 P-4279 PIGAR TRADING 330.64 12/9/2016 P-4295 SANFORD MARKETING CORPORATION 266.22 10/17/2016 P-4389 CEBU PORT AUTHORITY 107.88 Subtotal 4th Quarter 650,945.75 Total Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where the business address is incorrect, incomplete, or unreadable P757,094.16 6) Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where either there is no indicated business style or the indicated business style is incorrect 1st Quarter 1/26/2016 P-397 GORGEOUS FOODS, INC. P486.68 1/15/2016 P-444 PETRON XPRESSFILLSTATION 121.28 2/25/2016 P-454 TRAVELBEE MANAGEMENT CORPORATION 531.43 3/3/2016 P-491 ABACUS BOOK AND CARD CORP. 240 2/10/2016 P-500 GORGEOUS FOODS, INC. 175.06 2/17/2016 P-541 PLDT, INC. 756.26 2/18/2016 P-743 RIGHMONDE PLAZA CONDOMINIUM ASSOCIATION, INC. 766.8 1/15/2016 P-4792 GLOBAL SECURITY SOLUTIONS, INC. 341.51 3/1/2016 P-607 INNOVE COMMUNICATIONS, INC. 752.99 2/16/2016 P-636 D. MICHAEL CO INDUSTRIAL SUPPLY (DMC) CORP. 1,285.71 3/22/2016 P-658 GAC PHILIPPINES, INC. 38,069.40 2/19/2016 P-663 GAC PHILIPPINES, INC. 1,416.00 1/25/2016 P-669 GAC PHILIPPINES, INC. 1,724.00 2/26/2016 P-3252 TT & COMPANY, INC. 937.92 3/4/2016 P-2461 K-3 CENTERPOINT 168.32 3/4/2016 P-2465 MOTHERS CHOICE SURIGAO, INC. 170.21 3/4/2016 P-2477 TT & COMPANY, INC. 1,521.39 3/4/2016 P-3415 SILICON VALLEY 166.08 3/7/2016 P-3431 PACIFIC CATV, INC. 142.5 2/26/2016 P-3785 TRAVELBEE 648 3/1/2016 P-3795 SUPERVALUE, INC. 149.67 Subtotal 1st Quarter 50,571.21 2nd Quarter 6/20/2016 P-387 CEBU GOLDEN RESTAURANT, INC. 254.68 4/15/2016 P-737 RICHMONDE PLAZA CONDOMINIUM ASSOCIATION, INC. 766.8 6/17/2016 P-4781 GLOBAL SECURITY SOLUTIONS, INC. 323.64 5/31/2016 P-4783 GLOBAL SECURITY SOLUTIONS, INC. 675.32 5/6/2016 P-4785 GLOBAL SECURITY SOLUTIONS, INC. 323.64 6/13/2016 P-604 INNOVE COMMUNICATIONS, INC. 448.28 4/28/2016 P-605 INNOVE COMMUNICATIONS, INC. 390.42 4/18/2016 P-606 INNOVE COMMUNICATIONS, INC. 404.35 6-10/2016 P-647 GAC PHILIPPINES, INC. 12,720.00 4/15/2016 P-652 GAC PHILIPPINES, INC. 4,726.87 4/15/2016 P-653 GAC PHILIPPINES, INC. 1,497.25 4/15/2016 P-656 GAC PHILIPPINES, INC. 2,889.00 4/15/2016 P-657 GAC PHILIPPINES, INC. 2,296.43 6/1/2016 P-589 PEAR ENTERPRISES 70,470.00 6/28/2016 P-911 SANFORD MARKETING CORPORATION 289.37 6/30/2016 P-917 GOODHOPE HARDWARE 132.59 6/22/2016 P-955 ULTIMA RESIDENCES CONDOMINIUM CORPORATION 439.5 6/22/2016 P-958 PACIFIC CATV, INC. 256.5 6/21/2016 P-959 CHIKA-AN SA CEBU RESTAURANT 292.39 6/16/2016 P-963 ACE HARDWARE PHILIPPINES, INC. 259.68 6/19/2016 P-976 TRAVELBEE 478.29 6/24/2016 P-977 TRAVELBEE 239.14 6/24/2016 P-980 PRIVIS CORPORATION 308.04 6/18/2016 P-996 CEBU PRIMEGRILL CORP. 200.89 5/24/2016 P-1014 EJ'S GARDEN BY THE BAY 514.29 6/9/2016 P-1015 GRANDRESTO, INC. 513.64 6/10/2016 P-1016 HARRISON MILLER SCHWARTZ CORP. 107.14 6/3/2016 P-1018 PACIFIC CATV, INC. 267.32 6/3/2016 P-1019 ULTIMA RESIDENCES CONDOMINIUM CORPORATION 687.3 6/8/2016 P-1026 GOODHOPE HARDWARE 203.57 5/30/2016 P-1032 GOODHOPE HARDWARE 174.11 5/26/2016 P-1046 SANFORD MARKETING CORPORATION 134.33 6/6/2016 P-1047 THE FIRST FAMILY APPLIANCE CIRCLE CORP. 3,132.75 6/6/2016 P-1049 AKROASIA PETRON SERVICE STATION 214.29 6/7/2016 P-1060 GOODHOPE HARDWARE 599.46 6/6/2016 P-1065 GOODHOPE HARDWARE 327.32 6/14/2016 P-1069 PAGES HOLDINGS, INC. 169.82 4/7/2016 P-1296 CHOWKING 218.79 4/7/2016 P-1301 JOLLIBEE MCIAA 150.64 5/3/2016 P-1359 DUNKIN DONUTS 192.86 5/3/2016 P-1361 ROBINSONS SUPERMARKET CORPORATION 191.79 5/2/2016 P-2287 TAALEA RESORTS CORPORATION 161.79 5/5/2016 P-2290 AEROPHONE ENTERPRISES & CO. 107.14 4/25/2016 P-2291 AEROPHONE ENTERPRISES & CO. 107.14 5/6/2016 P-2294 SANFORD MARKETING CORPORATION 157.61 5/10/2016 P-2298 ESPRUTINGKLE GAS & SERVICE, INC. 168.23 5/7/2016 P-2305 MANDAUE FOAM INDUSTRIES, INC. 3,185.09 5/11/2016 P-2312 PACIFIC CATV, INC. 267.32 5/16/2016 P-2314 ESPRUTINGKLE GAS & SERVICE, INC. 179.05 5/13/2016 P-2315 GRANDRESTO, INC. 342.43 5/17/2016 P-2319 PRIME CARE CEBU 150 5/23/2016 P-2335 COKALING SHIPPING LINES, INC. 1,075.88 5/17/2016 P-2346 ESPRUTINGKLE GAS & SERVICE, INC. 1,039.50 5/6/2016 P-2370 VARLIZON, INC. 107.14 6/29/2016 P-2491 IRON CITY CALTEX STATION 200.89 6/17/2016 P-2507 IRON CITY CALTEX STATION 167.14 6/17/2016 P-2537 MOTHERS CHOICE SURIGAO, INC. 151.07 6/17/2016 P-2538 MOTHERS CHOICE SURIGAO, INC. 110.36 6/17/2016 P-2545 TT & COMPANY, INC. 954.62 6/24/2016 P-2549 MOTHERS CHOICE SURIGAO, INC. 144.64 6/24/2016 P-2551 MOTHERS CHOICE SURIGAO, INC. 171.54 6/10/2016 P-2568 MOTHERS CHOICE SURIGAO, INC. 188.89 6/10/2016 P-2571 MOTHERS CHOICE SURIGAO, INC. 484.93 6/10/2016 P-2583 IRON CITY CALTEX STATION 214.29 6/24/2016 P-2584 TT & COMPANY, INC. 853.74 6/2/2016 P-2595 B2Y'S AUTO SUPPLY & GENERAL MERCHANDISE 139.29 6/2/2016 P-2596 B2Y'S AUTO SUPPLY & GENERAL MERCHANDISE 139.29 6/7/2016 P-2614 SURIGAO FAIR TRADE 381.86 4/22/2016 P-2761 THE BELLEVUE MANILA 194.36 4/20/2016 P-2765 PACIFIC CATV, INC. 133.93 4/20/2016 P-2766 PACIFIC CATV, INC. 406.07 4/21/2016 P-2769 VESCORP BUSINESS OFFICE & SCHOOL SUPPLIES 146.25 4/7/2016 P-2777 NATIONAL BOOK STORE 706.9 4/6/2016 P-2797 NEWSAN TRADING LTD. CO. 2,271.21 4/19/2016 P-2799 NEWSAN TRADING LTD. CO. 1,012.50 4/15/2016 P-2802 ESPRUTINGKLE GAS & SERVICE, INC. 180.54 4/18/2016 P-2806 VESCORP BUSINESS OFFICE & SCHOOL SUPPLIES 502.5 5/28/2016 P-2807 IRON CITY CALTEX STATION 255 5/31/2016 P-2809 CENTERPOINT PETRON STATION 159.43 5/14/2016 P-2887 IRON CITY CALTEX STATION 107.14 5/17/2016 P-2890 IRON CITY CALTEX STATION 124.25 5/20/2016 P-2891 IRON CITY CALTEX STATION 127.29 5/4/2016 P-2892 IRON CITY CALTEX STATION 107.14 5/5/2016 P-2893 IRON CITY CALTEX STATION 107.14 5/7/2016 P-2897 IRON CITY CALTEX STATION 159.96 5/6/2016 P-2901 MOTHERS CHOICE SURIGAO, INC. 175.76 5/6/2016 P-2902 MOTHERS CHOICE SURIGAO, INC. 304.18 5/6/2016 P-2903 TT & COMPANY, INC. 720.81 5/6/2016 P-2904 MOTHERS CHOICE SURIGAO, INC. 120.92 5/12/2016 P-2907 TT & COMPANY, INC. 774.89 4/22/2016 P-3098 MOTHERS CHOICE SURIGAO, INC. 151.75 5/18/2016 P-3570 SUPERVALUE, INC. 111.99 5/23/2016 P-3607 PHILIPPINE INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS 360 4/30/2016 P-3634 SUPERVALUE, INC. 115.04 4/6/2016 P-4018 TOYOTA PASIG 296.35 6/6/2016 P-4396 ORIENTAL PORT AND ALLIED SERVICES CORP. 1,237.08 6/6/2016 P-4397 ORIENTAL PORT AND ALLIED SERVICES CORP. 181.92 Subtotal 2nd Quarter 131,485.66 3rd Quarter 9/19/2016 P-380 WATERFRONT AIRPORT HOTEL AND CASINO 728.57 8/9/2016 P-408 CITRA METRO MANILA TOLLWAYS CORPORATION 214.29 8/10/2016 P-3254 BRYON INDUSTRIAL SALES & SERVICES 1,836.00 8/16/2016 P-531 PLDT, INC. 795.93 7/18/2016 P-532 PLDT, INC. 756.26 7/18/2016 P-734 RICHMONDE PLAZA CONDOMINIUM ASSOCIATION, INC. 766.8 7/15/2016 P-4777 GLOBAL SECURITY SOLUTIONS, INC. 541.99 9/23/2016 P-601 INNOVE COMMUNICATIONS, INC. 1,029.42 9/30/2016 P-576 PEAR ENTERPRISES 167,460.00 8/27/2016 P-578 PEAR ENTERPRISES 47,280.00 8/11/2016 P-583 PEAR ENTERPRISES 83,700.00 9/20/2016 P-353 GLOBE TELECOM, INC. 3,238.06 8/27/2016 P-768 ALAIN ASIA TRADING CORPORATION 169.29 8/19/2016 P-805 TRAVELBEE 956.57 8/20/2016 P-808 PACIFIC CATV, INC. 142.5 8/2/2016 P-823 IKITCHEN, INC. 209.84 7/31/2016 P-824 WELL LOVED SEAFOOD HARVEST, INC. 116.79 8/9/2016 P-826 NISSAN CEBU DISTRIBUTORS, INC. 504.11 8/10/2016 P-834 THE FIRST FAMILY APPLIANCE CIRCLE CORP. 1,403.57 8/9/2016 P-835 ACE HARDWARE PHILIPPINES, INC. 130.07 8/8/2016 P-837 GOODHOPE HARDWARE 126.16 8/11/2016 P-839 VINUTECH DIGITAL CORP. 385.71 7/29/2016 P-860 PACIFIC CATV, INC. 142.5 7/20/2016 P-867 AKROASIA PETRON SERVICE STATION 190.12 7/21/2016 P-873 PYEZA PARTS DEPOT, INC. 365.89 7/27/2016 P-887 ACE HARDWARE PHILIPPINES, INC. 149.97 7/27/2016 P-888 AKROASIA PETRON SERVICE STATION 177.62 7/22/2016 P-891 SANFORD MARKETING CORPORATION 133.23 7/4/2016 P-898 ULTIMA RESIDENCES CONDOMINIUM CORPORATION 159 7/8/2016 P-904 ALAIN ASIA TRADING CORPORATION 212.14 7/1/2016 P-927 DHL EXPRESS (PHILIPPINES) CORP. 468.01 7/12/2016 P-929 AKROASIA PETRON SERVICE STATION 205.83 7/13/2016 P-932 ACE HARDWARE PHILIPPINES, INC. 139.23 7/14/2016 P-938 THE FIRST FAMILY APPLIANCE CIRCLE CORP. 1,606.61 7/15/2016 P-940 GOODHOPE HARDWARE 165.54 7/6/2016 P-948 AEROPHONE ENTERPRISES & CO. 107.14 7/29/2016 P-1922 SURIGAO M.S. ENTERPRISES 133.93 7/22/2016 P-1968 TT & COMPANY, INC. 1,003.40 7/8/2016 P-2004 TRI-MIX ENTERPRISES 303.21 7/8/2016 P-2005 SURIGAO GLASSMASTER 160.71 7/8/2016 P-2010 DMC 289.29 7/7/2016 P-2012 SOLARIS GAS SERVICE STATION 195.21 7/11/2016 P-2019 K3CP CORPORATION 131.14 7/1/2016 P-2023 TT & COMPANY, INC. 910.99 7/1/2016 P-2031 WINSHER MARKETING 220.71 7/8/2016 P-2048 TT & COMPANY, INC. 1,519.48 9/25/2016 P-2646 MOTHERS CHOICE SURIGAO, INC. 833.6 8/19/2016 P-2956 MOTHERS CHOICE SURIGAO, INC. 459.02 8/19/2016 P-2958 TT & COMPANY, INC. 1,057.15 8/12/2016 P-2983 MOTHERS CHOICE SURIGAO, INC. 471.21 8/3/2016 P-3000 CITI HARDWARE BACOLOD, INC. 183.29 8/6/2016 P-3008 IRON CITY CALTEX STATION 205.71 8/10/2016 P-3022 LAVENDER SHELL SERVICE STATION & GEN. MDSE. 107.14 8/5/2016 P-3030 TT & COMPANY, INC. 1,225.62 8/5/2016 P-3036 MOTHERS CHOICE SURIGAO, INC. 346.07 8/5/2016 P-3037 MOTHERS CHOICE SURIGAO, INC. 109.29 8/5/2016 P-3038 MOTHERS CHOICE SURIGAO, INC. 257.56 9/10/2016 P-3206 ROBINSONS SELECTIONS 259.18 9/14/2016 P-3211 AKROASIA PETRON SERVICE STATION 197.59 9/27/2016 P-3238 AKROASIA PETRON SERVICE STATION 185.29 7/25/2016 P-3593 AMICUS CATERING SERVICES & SUPPLIES 1,989.64 8/11/2016 P-3600 CEBU AIR, INC. 278.57 8/8/2016 P-3603 PHILIPPINE INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS 180 8/10/2016 P-3720 IKITCHEN, INC. 308.57 8/3/2016 P-3722 DHL EXPRESS 124.82 7/20/2016 P-3822 RED PLANET HOTELS ORTIGAS CORPORATION 870.42 9/30/2016 P-4081 ACCENT MICRO PRODUCTS, INC. 1,446.43 7/4/2016 P-4141 PRIME ARCH CREATIVE RESTAURANTS, INCORPORATED 107.57 7/4/2016 P-4143 JOLLIBEE ROBINSONS PALAWAN 141.75 9/8/2016 P-4198 DHL EXPRESS CORP. 124.82 9/16/2016 P-4394 GALCO 1,502.95 Subtotal 3rd Quarter 334,556.09 4th Quarter 11/18/2016 P-450 PHILIPPINE AIRLINES 549.82 10/19/2016 P-451 PHILIPPINE AIRLINES 1,084.96 10/14/2016 P-452 PHILIPPINE AIRLINES 867.14 10/3/2016 P-534 PLDT, INC. 1,192.07 10/13/2016 P-546 NEWSAN TRADING LTD. CO. 843.21 11/23/2016 P-750 GLOBAL SECURITY SOLUTIONS, INC. 259.74 11/11/2016 P-752 GLOBAL SECURITY SOLUTIONS, INC. 259.74 10/15/2016 P-572 LINCOLN REALTY CORP. 3,214.29 11/17/2016 P-573 LINCOLN REALTY CORP. 3,214.29 11/24/2016 P-1471 NEW VENTURES SHELL STATION 163.25 11/10/2016 P-1491 AKROASIA PETRON SERVICE STATION 206.09 12/5/2016 P-1768 REDD MOBILE MARKETING 589.29 12/2/2016 P-1800 MOTHERS CHOICE SURIGAO, INC. 114.21 12/2/2016 P-1801 MOTHERS CHOICE SURIGAO, INC. 130.18 12/2/2016 P-1802 MOTHERS CHOICE SURIGAO, INC. 385.42 12/2/2016 P-1803 TT AND COMPANY, INC. 666.37 12/9/2016 P-1809 TT AND COMPANY, INC. 1,293.81 12/9/2016 P-1812 MOTHERS CHOICE SURIGAO, INC. 441.88 12/16/2016 P-1834 MOTHERS CHOICE SURIGAO, INC. 133.39 12/16/2016 P-1836 MOTHERS CHOICE SURIGAO, INC. 111.43 12/16/2016 P-1837 MOTHERS CHOICE SURIGAO, INC. 392.26 12/16/2016 P-1841 TT AND COMPANY, INC. 982.88 12/17/2016 P-1857 K3CP CORPORATION 145.39 12/23/2016 P-1880 MOTHERS CHOICE SURIGAO, INC. 258.06 12/23/2016 P-1883 TT AND COMPANY, INC. 522.79 12/30/2016 P-1893 ROBINSONS SUPERMARKET CORPORATION 674.96 10/14/2016 P-2120 MOTHERS CHOICE SURIGAO, INC. 317.92 10/14/2016 P-2122 MOTHERS CHOICE SURIGAO, INC. 447.37 10/14/2016 P-2125 TT & COMPANY, INC. 1,351.99 10/11/2016 P-2142 NEW SURIGAO PAINTHAUS & AUTOPARTS GEN. MERCHANDISE 535.71 10/11/2016 P-2144 B2Y'S AUTO SUPPLY AND GENERAL MERCHANDISE 160.71 10/13/2016 P-2149 K3CP CORPORATION 119.36 10/7/2016 P-2160 MOTHERS CHOICE SURIGAO, INC. 536.32 10/7/2016 P-2161 MOTHERS CHOICE SURIGAO, INC. 308.61 10/7/2016 P-2162 MOTHERS CHOICE SURIGAO, INC. 156.43 10/7/2016 P-2163 TT & COMPANY, INC. 1,364.58 10/2/2016 P-2180 PARKWAY 392.72 10/6/2016 P-2188 REDD MOBILE MARKETING 492.86 10/1/2016 P-2198 ROBINSON'S SUPERMARKET CORPORATION 1,139.90 11/4/2016 P-2216 TT & COMPANY, INC. 992.65 11/21/2016 P-2252 B2Y'S AUTO SUPPLY & GENERAL MERCHANDISE 2,229.64 11/18/2016 P-2260 TT & COMPANY, INC. 928.13 11/18/2016 P-2261 MOTHERS CHOICE SURIGAO, INC. 629.44 11/29/2016 P-2272 SURIGAO MEDICAL CENTER, INC.-PHARMACY 129.56 11/25/2016 P-2277 MOTHERS CHOICE SURIGAO, INC. 458.01 11/25/2016 P-2280 TT & COMPANY, INC. 810.05 12/16/2016 P-3481 CEBU AIR, INC. 172.92 10/3/2016 P-4087 CITRA METRO MANILA TOLLWAYS CORPORATION 107.14 11/14/2016 P-4242 SUPERGAS MEGA GAS STATION 170.63 11/18/2016 P-4262 CK OF ASIA, INC. 76.87 12/4/2016 P-4269 ROBINSON'S DEPARTMENT STORE-BUTUAN 192.86 12/4/2016 P-4271 ROBINSON'S DEPARTMENT STORE-BUTUAN 385.71 12/4/2016 P-4272 ROBINSON'S DEPARTMENT STORE-BUTUAN 412.5 12/4/2016 P-4273 ROBINSON'S DEPARTMENT STORE-BUTUAN 2,035.71 12/9/2016 P-4274 BENCH BOUTIQUE 136.74 12/9/2016 P-4278 TT & COMPANY, INC. 224.76 12/15/2016 P-4287 PARKWAY 139.33 12/8/2016 P-4291 SUPERVALUE, INC. 267.27 12/8/2016 P-4293 THE SM STORE 861.27 12/9/2016 P-4294 ROBINSON'S SUPERMARKET CORPORATION 176.21 12/13/2016 P-4307 V.C.M. TRADING 241.07 10/11/2016 P-4383 J CO DONUTS AND COFFEE 107.68 10/14/2016 P-4384 GAC PHILIPPINES, INC. 39,000.00 10/14/2016 P-4385 GAC PHILIPPINES, INC. 17,520.00 10/14/2016 P-4392 GAC PHILIPPINES, INC. 1,786.79 10/6/2016 P-4400 CEBU PORT AUTHORITY 218.88 12/2/2016 P-4402 GAC PHILIPPINES, INC. 7,632.11 10/18/2016 P-4425 CUBIXOFFICE 187.5 Subtotal 4th Quarter 104,252.83 Total Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where either there is no indicated business style or the indicated business style is incorrect P620,865.79 7) Input VAT on domestic purchase of goods/services supported by a document with "NOT VALID FOR CLAIMING INPUT TAXES" remark 1st Quarter 2/6/2016 P-1582 CEBUANO'S TAILOR P53.57 Subtotal 1st Quarter 53.57 Total Input VAT on domestic purchase of goods/services supported by a document with "NOT VALID FOR CLAIMING INPUT TAXES" remark P53.57 8) Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where ATP details are not indicated and/or unreadable or the ATP is expired 1st Quarter 2/12/2016 P-1594 MOTHERS CHOICE SURIGAO, INC. P137.13 2/12/2016 P-1596 MOTHERS CHOICE SURIGAO, INC. 417.1 3/24/2016 P-2381 ULING ROASTERS 57.86 2/15/2016 P-3762 GRANT LINE, INC. 32.36 2/5/2016 P-3929 JOLLIBEE 10.61 1/29/2016 P-3951 JOLLIBEE 8.79 2/2/2016 P-3955 MR. KIMBOB BIBIMBOB, INC. 10.61 Subtotal 1st Quarter 674.46 2nd Quarter 6/3/2016 P-1023 SM PRIME HOLDINGS, INC. 2.68 6/30/2016 P-2492 K3CP CORPORATION 153 6/17/2016 P-2508 HONEYLEMON FOODS, INC. 13.39 6/24/2016 P-2533 CHOWKING 25.82 6/17/2016 P-2535 MOTHERS CHOICE SURIGAO, INC. 404.47 6/24/2016 P-2552 MOTHERS CHOICE SURIGAO, INC. 378.76 6/10/2016 P-2569 MOTHERS CHOICE SURIGAO, INC. 106.18 5/27/2016 P-2871 JANET TE LAGUA 31.61 5/20/2016 P-2884 MOTHERS CHOICE SURIGAO, INC. 136.61 4/20/2016 P-3069 HONEYLEMON FOODS, INC. 51.86 4/29/2016 P-3082 K3CP CORPORATION 55.82 4/29/2016 P-3084 BABIELYN KITCHENETTE 76.61 4/22/2016 P-3099 MOTHERS CHOICE SURIGAO, INC. 368.6 4/30/2016 P-3115 MOTHERS CHOICE SURIGAO, INC. 496.34 4/30/2016 P-3117 MOTHERS CHOICE SURIGAO, INC. 105.2 4/8/2016 P-4027 MC KINLEY FOOD EXPRESS, INC. 10.61 4/26/2016 P-4052 CHOWKING 10.61 Subtotal 2nd Quarter 2,428.17 3rd Quarter 7/20/2016 P-863 AKROASIA PETRON SERVICE STATION 12.32 7/8/2016 P-2008 HONEYLEMON FOODS, INC. 10.61 9/25/2016 P-2645 TAIPAN DEVELOPMENT, INC. 55.97 9/22/2016 P-3225 RED RIBBON 75 Subtotal 3rd Quarter 153.9 4th Quarter 12/9/2016 P-1811 MOTHERS CHOICE SURIGAO, INC. 88.93 10/14/2016 P-2121 MOTHERS CHOICE SURIGAO, INC. 43.39 10/14/2016 P-2123 MOTHERS CHOICE SURIGAO, INC. 160.71 10/16/2016 P-2155 ROBINSONS DEPARTMENT STORE 5.36 11/21/2016 P-2249 CHOWKING-SURIGAO DOWNTOWN 21.11 Subtotal 4th Quarter 319.5 Total Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where ATP details are not indicated and/or unreadable or the ATP is expired P3,576.03 9) Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where alterations were made without authorized countersignature 1st Quarter 2/1/2016 P-382 TRAVELBEE MANAGEMENT CORPORATION P265.71 2/12/2016 P-4794 GLOBAL SECURITY SOLUTIONS, INC. 1,042.73 2/27/2016 P-1737 PRUDENTIAL CUSTOMS BROKERAGE SERVICES, INC. 5.16 3/23/2016 P-2376 PARKWAY 115.79 3/18/2016 P-2413 GREENWICH 149.46 2/24/2016 P-3433 MA. LINA CATERING SERVICES 514.29 2/24/2016 P-3434 ESPRUTINGKLE GAS & SERVICE, INC. 10.71 3/2/2016 P-3878 JOLLIBEE FOOD CORPORATION 8.79 3/18/2016 P-3907 MANG INASAL RESTAURANT 11.89 Subtotal 1st Quarter 2,124.53 2nd Quarter 5/8/2016 P-381 THE BELLEVUE MANILA 4,903.15 6/20/2016 P-953 MANDAUE STAR OIL GASOLINE STATION & CONVENIENT STORE 68.46 6/8/2016 P-1028 GOODHOPE HARDWARE 19.07 5/23/2016 P-2309 CEBU ADGEM AUTO PARTS 6.96 5/18/2016 P-2311 NIKKIE POLLUTION TEST CO. 32.14 5/23/2016 P-2327 AKROASIA PETRON SERVICE STATION 214.93 5/23/2016 P-2331 CALOOCAN BEARING AND PARTS CORP. 22.5 4/24/2016 P-2368 MAPECON PHILIPPINES, INC. 267.86 6/26/2016 P-2560 ULING ROASTERS 57.86 6/24/2016 P-2563 ULING ROASTERS 77.14 4/8/2016 P-2787 ESPRUTINGKLE GAS & SERVICE, INC. 10.71 4/13/2016 P-2798 NEWSAN TRADING LTD. CO. 843.75 5/2/2016 P-2851 ULING ROASTERS 250.71 5/27/2016 P-2853 MOTHERS CHOICE SURIGAO, INC. 133.39 5/27/2016 P-2855 ULING ROASTERS 57.86 6/26/2016 P-2870 CHOWKING 17.79 6/24/2016 P-3554 HI-SERVE PETROLEUM RETAILERS 53.57 4/2/2016 P-4005 SLT GASMART CORPORATION 6.43 4/3/2016 P-4009 SM HYPERMARKET 152.61 4/7/2016 P-4023 MUY BIEN FOODS CORPORATION 9.11 4/21/2016 P-4042 KNOXPORT, INC. 10.61 Subtotal 2nd Quarter 7,216.62 3rd Quarter 8/9/2016 P-409 PETRON XPRESSFILLSTATION 107.16 9/22/2016 P-754 GLOBAL SECURITY SOLUTIONS, INC. 536.8 8/18/2016 P-630 D. MICHAEL CO INDUSTRIAL SUPPLY (DMC) CORP. 11,416.07 7/27/2016 P-885 AKROASIA PETRON SERVICE STATION 13.16 7/22/2016 P-1960 JOLLIBEE 39.86 7/1/2016 P-2028 MOTHERS CHOICE SURIGAO, INC. 417.37 9/30/2016 P-2618 CABADBARAN SHELL SERVICE STATION 107.14 9/30/2016 P-2619 ASM FOODS 13.82 8/5/2016 P-3002 LAVENDER SHELL SERVICE STATION & GEN. MDSE 10.71 8/30/2016 P-3167 CBX 1,496.25 8/31/2016 P-3168 AKROASIA PETRON SERVICE STATION 214.14 8/31/2016 P-3181 CEBU PORT AUTHORITY 2.89 9/8/2016 P-3199 SANFORD MARKETING CORPORATION 79.07 9/8/2016 P-3204 AKROASIA PETRON SERVICE STATION 141.44 9/14/2016 P-3210 AEROPHONE ENTERPRISES & CO. 107.14 9/20/2016 P-3218 ESPRUTINGKLE GAS & SERVICES, INC. 1,069.93 9/22/2016 P-3226 LAVSHELL SERVICE STATION 155.64 8/30/2016 P-4162 RUFO'S FAMOUS TAPA 13.5 8/30/2016 P-4165 MQUAD SOLUTIONS, INC. 256.07 8/31/2016 P-4166 SUPERVALUE, INC. 124.31 8/31/2016 P-4167 BLUE BOZ 4.29 9/2/2016 P-4176 TROPICAL HUT HAMBURGER 8.46 9/2/2016 P-4178 MICHEAL T. TAGORDA 10.71 9/5/2016 P-4182 MQUAD SOLUTIONS, INC. 256.07 9/6/2016 P-4187 SAM HIRANAND FOOD CORPORATION 25.71 9/9/2016 P-4191 SAM HIRANAND FOOD CORPORATION 11.79 Subtotal 3rd Quarter 16,639.51 4th Quarter 10/13/2016 P-577 PEAR ENTERPRISES 51,980.00 10/10/2016 P-1523 AKROASIA PETRON SERVICE STATION 214.29 10/14/2016 P-1536 THE FIRST FAMILY APPLIANCE CIRCLE CORP. 2,538.75 12/5/2016 P-3706 ERNA GASOLINE STATION 10.71 11/15/2016 P-4256 MOMS FLOWERSHOPPE 21.22 12/7/2016 P-4301 SODEXO BENEFITS AND REWARDS SERVICES PHILIPPINES, INC. 5,713.71 Subtotal 4th Quarter 60,478.69 Total Input VAT on domestic purchase of goods/services supported by VAT Invoice/OR where alterations were made without authorized countersignature P86,459.35 10) Input VAT on domestic purchase of goods/services supported by Non-VAT Invoice/OR 1st Quarter 3/17/2016 P-539 PLDT, INC. P756.26 2/17/2016 P-540 PLDT, INC. 364.83 Subtotal 1st Quarter 1,121.09 Total Input VAT on domestic purchase of goods/services supported by Non-VAT Invoice/OR P1,121.09 Total input VAT on Domestic Purchases Not Properly Substantiated P1,562,076.91 With regard to the refund of input VAT on importation of goods other than capital goods in the total amount of P3,570,947.00, it is important to emphasize that to be entitled to its claim, petitioner must prove, among others, (i) the fact of importation; and, (ii) the payment of VAT on said importation. It must be noted that the Court denied admission in evidence 50 petitioner's Exhibit Nos. "P-3255" to "P-3271", with sub-markings, which pertains to the Bureau of Customs' Single Administrative Documents (SAD) and Statement of Settlement of Duties and Taxes (SSDT) on its alleged importation of goods. Without the SAD and SSDT, the Court cannot ascertain the fact of importation and the payment of VAT on such importation. Thus, the input VAT on importations in the total amount of P3,570,947.00 shall be disallowed, as follows: Import Entry No. Exhibit No. OR No. Date of VAT Payment Input VAT 1st Quarter C-2368 P-3255 to P-3255-E, P-3860 R-5299 1/27/2016 P27,123.00 C-2304 P-3256 to P-3256-c, P-3861 R-9558 2/15/2016 60,208.00 C-367 P-3257 to P-3257-G, P-3861 R-7376 2/1/2016 88,576.00 C-36901 P-3258, P-3862 150971 3/15/2016 717,960.00 C-994 P-3259 to P-3259-F, P-3862 R-19988 3/21/2016 47,397.00 Subtotal 1st Quarter P941,264.00 2nd Quarter C-11595 P-3260 to P-3260-D, P-3272, P-4750-A R-22751 4/26/2016 290,294.00 C-1200 P-3261 to P-3261-E, P-3272, P-4751 R-23688 4/7/2016 55,031.00 C-15522 P-3262, P-3864 R-30588 6/3/2016 27,775.00 C-15560 P-3263 to P-3263-I, P-3864 R-30433 6/2/2016 896,014.00 C-15671 P-3264 to P-3264-E, P-3864 R-30767 6/3/2016 258,063.00 Subtotal 1st Quarter P1,527,177.00 3rd Quarter C-2434 P-3265 to P-3265-D, P-3865 R-46324 7/1/2016 57,260.00 C-3829 P-3266, P-3867 R-65981 9/15/2016 126,754.00 Subtotal 3rd Quarter P184,014.00 4th Quarter C-30184 P-3267, P-3868 R-65981 10/17/2016 59,364.00 C-4249 P-3268, P-3869 R-72605 10/13/2016 179,107.00 C-4785 P-3269, P-3869 R-81085 11/21/2016 44,420.00 C-37240 P-3270, P-3870 R-70074 12/12/2016 137,970.00 C-5146 P-3271, P-3870 R-86195 12/13/2016 497,631.00 Subtotal 4th Quarter 918,492.00 Total Input VAT on Importations Not Supported by Admitted Evidence P3,570,947.00 The total disallowances per the Court's further verification of petitioner's input taxes for the four quarters of TY 2016 is P5,133,023.91, computed as follows: 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total Input VAT on Domestic Purchases Not Properly Substantiated P104,849.85 P245,287.73 P376,323.87 P835,615.46 P1,562,076.91 Input VAT on Importations Not Supported by Admitted Evidence 941,264.00 1,527,177.00 184,014.00 918,492.00 3,570,947.00 Total Disallowances per Court's further verification P1,046,113.85 P1,772,464.73 P560,337.87 P1,754,107.46 P5,133,023.91 In view of the foregoing disallowances, the total valid input taxes of petitioner subject for allocation is P342,472.59, as shown below: cHDAIS 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total Total Input VAT P1,338,962.78 P2,085,465.00 P970,264.20 P2,367,866.07 P6,762,558.05 Less: Disallowance per ICPA Exception 338,285.47 150,499.55 189,997.23 79,414.02 758,196.27 Disallowance per Court's Further Verification 1,046,113.85 1,772,464.73 560,337.87 1,754,107.46 5,133,023.91 Valid Common Input Tax for Allocation (45,436.54) 162,500.72 219,929.10 534,344.59 871,337.87 Less: Input Tax on Unaccounted Purchases 528,865.28 Net Valid Common Input Tax for Allocation P342,472.59 Considering that petitioner is engaged in taxable sales subject to both 0% and 12% VAT, and its input VAT cannot be directly or entirely attributed to any of the transactions, the valid common input VAT of P342,472.59 shall be proportionately allocated on the basis of the volume of its sales in accordance with Section 112 (A) of the NIRC of 1997, as amended, thus: Total VATable Sales per Quarterly VAT Returns P14,624,302.04 Divided by Total Declared Sales per Quarterly VAT Returns 97,802,307.14 Multiplied by Total Valid Input VAT 342,472.59 Input VAT Allocated to Total VATable Sales P51,209.66 Total Zero-rated Sales per Quarterly VAT Returns P83,178,005.10 Divided by Total Declared Sales per Quarterly VAT Returns 97,802,307.14 Multiplied by Total Valid Input VAT 342,472.59 Input VAT Allocated to Zero-rated Sales P291,262.93 Thus, petitioner has valid input VAT attributable to its zero-rated sales in the amount of P291,262.93. Sixth Requisite: Petitioner has no excess input VAT available for refund Having determined that petitioner had valid input VAT attributable to its zero-rated sales, the Court shall now determine whether the same was not applied against its output VAT liability. After deducting the input tax attributable to VATable sales in the amount of P51,209.66 from its output VAT liability of P1,754,936.25 from the said sales, petitioner still has a net output VAT payable of P1,703,726.59 , as computed below: Period Output VAT 1st Quarter P428,487.15 2nd Quarter 377,688.44 3rd Quarter 556,167.00 4th Quarter 392,593.69 Total P1,754,936.25 Output VAT per Returns P1,754,936.25 Less: Input VAT Allocated to Total VATable Sales 51,209.66 Net Output VAT Payable P1,703,726.59 Since petitioner's input VAT attributable to VATable sales is not enough to cover its output VAT liability, the valid input VAT attributable to zero-rated sales shall be utilized against the remaining output VAT liability of P1,703,726.59. However, the input VAT attributable to zero-rated sales of P291,262.93 is way lower than the net output VAT payable of P1,703,726.59. Consequently, petitioner still has net output VAT due of P1,412,463.66 , computed as follows: ISHCcT Net Output VAT Payable P1,703,726.59 Less: Input VAT Allocated to Zero-rated Sales 291,262.93 Net Output VAT Still Due P1,412,463.66 While the Court notes that petitioner's 1st Quarterly VAT Return for TY 2016 reflected the amount of P4,249,849.48 as "Input Tax Carried Over from Previous Period," petitioner failed to submit documents, official receipts and invoices to support the input tax carry-over of P4,249,849.48. Hence, petitioner's input tax carried over from previous period cannot be validly applied against petitioner's net output VAT due pursuant to Section 110 (A) in relation to Section 110 (B) of the NIRC of 1997, as amended. Verily, in claiming excess or unutilized input VAT from zero-rated transactions, it is the excess over the output VAT which should be refunded to the taxpayer or credited against other internal revenue taxes. It is important for the taxpayer to prove that it has enough prior year's excess input VAT credits to cover its output VAT liability for the current taxable year. To reiterate, in cases filed before this Court, which are litigated de novo , party-litigants must prove every minute aspect of their case. 51 Consequently, there being no excess input VAT which may be the subject of a claim for refund or issuance of tax credit certificate, the present claim must be denied. Finally, it bears stressing that a claimant has the burden of proof to establish the factual basis of his or her claim for tax credit or refund. 52 Tax refunds are in the nature of tax exemptions. As such, they are regarded as in derogation of sovereign authority and to be construed strictissimi juris against the person or entity claiming the refund. 53 The pieces of evidence presented entitling a taxpayer to an exemption are also strictissimi scrutinized and must be duly proven. 54 Hence, an applicant for a claim of tax refund or tax credit must not only prove entitlement to the claim but also compliance with all the documentary and evidentiary requirements. 55 WHEREFORE , in light of the foregoing, the Petition for Review filed on May 15, 2018 is hereby DENIED for lack of merit. SO ORDERED. (SGD.) ROMAN G. DEL ROSARIO Presiding Justice Catherine T. Manahan, J. , concurs. Footnotes 1. Par. 8, Petition for Review, CTA Docket vol. I, p. 19; and Exhibit "P-4-1", CTA Docket vol. VI, p. 3469. 2. Exhibit "P-2", CTA Docket vol. VI, p. 3442. 3. Par. 2, II. Statement of Facts and Issues, Pre-Trial Order, CTA Docket VI, p. 3082. 4. Exhibit "P-3-1", CTA Docket vol. VI, p. 3455. 5. Exhibit "P-3", CTA Docket vol. VI, pp. 3443-3453. 6. Exhibits "P-8", "P-9", "P-40" and "P-11", CTA Docket vol. VI, pp. 3489-3490, 3487-3488, 3485-3486 and 3483-3484. 7. Exhibit "P-5", CTA Docket vol. VI, p. 3477. 8. Exhibit "P-70", CTA Docket vol. VI, p. 3592. 9. CTA Docket vol. I, p. 12. 10. CTA Docket vol. V, p. 2299. 11. CTA Docket vol. V, pp. 2300-2305. 12. CTA Docket vol. V, pp. 2821-2823. 13. CTA Docket vol. V, pp. 2824-2856. 14. CTA Docket vol. V, pp. 2872-2874. 15. CTA Docket vol. V, pp. 3081-3094. 16. CTA Docket vol. V, pp. 2861-2865. 17. CTA Docket vol. V, pp. 3072-3077. 18. Exhibit "P-93", Judicial Affidavit of Jennilyn U. Gaanan, CTA Docket vol. V, pp. 2882-2905; and Minutes of Hearing dated May 21, 2019, CTA Docket vol. VI, pp. 3122-3123. 19. Exhibits "P-90" and "P-92", CTA Docket vols. V and VI, pp. 3053-3059 and 3355-3372; and Minutes of Hearing dated September 3, 2019, CTA Docket vol. VI, pp. 3384-3388. 20. CTA Docket vol. VI, pp. 3422-3439. 21. CTA Docket vol. VI, pp. 3603-3607. 22. CTA Docket vol. VI, pp. 3391-3392. 23. CTA Docket vol. VI, pp. 3609-3639. 24. CTA Docket vol. VI, p. 3608. 25. CTA Docket vol. VI, 3645. 26. Issue, Pre-Trial Order, CTA Docket vol. V, p. 3082. 27. An Act Amending Sections 5, 6, 24, 25, 27, 31, 32, 33, 34, 51, 52, 56, 57, 58, 74, 79, 84, 86, 90, 91, 97, 99, 100, 101, 106, 107, 108, 109, 110, 112, 114, 116, 127, 128, 129, 145, 148, 149, 151, 155, 171, 174, 175, 177, 178, 179, 180, 181, 182, 183, 186, 188, 189, 190, 191, 192, 193, 194, 195, 196, 197, 232, 236, 237, 249, 254, 264, 269, AND 288; Creating New Sections 51-A, 148-A, 150-A, 150-B, 237-A, 264-A, 264-B, and 265-A; and Repealing Sections 35, 62, and 89; All Under Republic Act No. 8424, Otherwise Known as the National Internal Revenue Code of 1997, as Amended, and for Other Purposes. 28. Exhibit "P-2", CTA Docket vol. VI, p. 3442. 29. March 31, 2018 fell on a Saturday. April 2, 2018 is the next working day. 30. An Act Creating the Court of Tax Appeals. 31. An Act Expanding the Jurisdiction of the Court of Tax Appeals (CTA), Elevating Its Rank to the Level of a Collegiate Court with Special Jurisdiction and Enlarging its Membership Amending for the Purpose Certain Sections of Republic Act No. 1125, as amended, otherwise known as the law creating the Court of Tax Appeals, and for Other Purposes. 32. G.R. No. 150154, August 9, 2005. 33. SUBJECT: Tax Treatment of Sales of Goods, Properties and Services Made by VAT-registered Suppliers to BOI-registered Manufacturers-Exporters With 100% Export Sales. 34. Sitel Philippines Corporation (Formerly Clientlogic Phils., Inc.) vs. Commissioner of Internal Revenue , G.R. No. 201326, February 8, 2017. 35. Commissioner of Internal Revenue vs. Burmeister and Wain Scandinavian Contractor Mindanao, Inc. , G.R. No. 153205, January 22, 2007; Commissioner of Internal Revenue vs. American Express International, Inc. (Philippine Branch) , G.R. No. 152609, June 29, 2005. 36. Commissioner of Internal Revenue vs. American Express International, Inc. (Philippine Branch), supra . 37. Commissioner of Internal Revenue vs. Burmeister and Wain Scandinavian Contractor Mindanao, Inc., supra . 38. Section 108 (B), NIRC of 1997, as amended. 39. Commissioner of Internal Revenue vs. Deutsche Knowledge Services Pte. Ltd. , G.R. No. 234445, July 15, 2020. 40. Commissioner of Internal Revenue vs. CITCO International Support Services Limited-Philippine ROHQ , CTA EB No. 2015, November 29, 2019. 41. Exhibit Nos. "P-8" to "P-11", CTA Docket vol. VI, pp. 3483-3491. 42. No figures reported in the Quarterly VAT Returns of TY 2016. Amounts were computed by the Court. 43. Exhibit "P-91", CTA Docket vol. VI, pp. 3213-3214. 44. Petition for Review, CTA Docket vol. I, pp. 22-23. 45. Tables XIV-A to XIV-E, Exhibit "P-91", CTA Docket vol. VI, pp. 3226-3230. 46. Exhibit "P-91", CTA Docket vol. VI, p. 3223. 47. P4,407,210.69 (VATable purchase) x 12% = P528,865.28. 48. Tables XIV-A to XIV-E, Exhibit "P-91", CTA Docket vol. VI, pp. 3226-3230. 49. Exhibit "P-91-E", CTA Docket vol. VI, pp. 3246-3278. 50. Resolution dated February 26, 2020, CTA Docket vol. VI, pp. 3603-3607. 51. Commissioner of Internal Revenue vs. United Salvage and Towage (Phils), Inc. , G.R. No. 197515, July 2, 2014. 52. Citibank N.A. vs. Court of Appeals and Commissioner of Internal Revenue , G.R. No. 107434, October 10, 1997. 53. Commissioner of Internal Revenue vs. S.C. Johnson and Son, Inc., et al. , G.R. No. 127105, June 25, 1999. 54. Kepco Philippines Corporation vs. Commissioner of Internal Revenue , G.R. No. 179961, January 31, 2011. 55. Eastern Telecommunications Philippines, Inc. vs. Commissioner of Internal Revenue , G.R. No. 183531, March 25, 2015.