Accounting Method by Court of Tax Appeals... EmelinoTMaestro.com

For the sale of goods or properties, the VAT is imposed upon the gross selling price which means that the VAT on the sale of goods or properties accrues upon the consummation of sale, whether or not the consideration was actually received already by the seller. On the other hand, in the sale of services, as in the instant case, the VAT is computed based on gross receipts as indicated in Section 108 (A). Therefore, the VAT on the sale of services accrues upon actual or constructive receipt of the consideration, whether or not the service has been rendered.
Considering that in a claim for issuance of a tax credit certificate attributable to zero-rated sales, what is to be closely scrutinized is its documentary substantiation, and since petitioner has not established by sufficient evidence its entitlement thereto, then its claim should be denied. The sales invoices and other commercial documents were not sufficient documentary proofs in lieu of what is mandated by the NIRC of 1997. Nippon Express (Philippines) Corporation v. Commissioner of Internal Revenue, C.T.A. EB No. 492 (C.T.A. Case No. 7429), December 15, 2009)....