Practice question
A supplier sells services to a registered export enterprise in 2026. It cites the destination principle and refuses to examine whether the services relate to the registered activity or whether current incentive conditions are met. The buyer’s registration alone is its entire basis. What is the soundest approach?
- Treat the principle as repealing all statutory conditions
- Examine the applicable zero-rating route and its conditions, including direct attribution where required
- Assume every service to any registered entity is exempt
- Treat all exports as ordinary local consumption
- Use an old case’s tax-period facts as a universal present exemption
Legal references
- CIR v. Seagate Technology, G.R. 153866, February 11, 2005 (destination principle): https://lawphil.net/judjuris/juri2005/feb2005/gr_153866_2005.html
- Maibarara Geothermal v. CIR, G.R. 250479, July 18, 2022: https://lawphil.net/judjuris/juri2022/jul2022/gr_250479_2022.html
- NIRC Sections 106,108,293(D),295(D), as amended by RA 12066, Sections 6-7,16,18: https://lawphil.net/statutes/repacts/ra2024/ra_12066_2024.html
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