Philippines: Guidelines for VAT Zero-Rating Certificate applications of PEZA-registered businesses simplified

In brief

The Philippine Economic Zone Authority (PEZA) issued Memorandum Order No. 2024-007 (Guidelines on the Application for the Issuance of VAT Zero-Rating Certificate) dated 28 November 2024 (VAT Zero-Rating Certificate Guidelines) to expedite the processing of applications for VAT Zero-Rating Certificates by removing the requirement to submit an Enterprise Services Division (ESD) clearance confirming registered business enterprises' (RBEs) submission of PEZA reportorial requirements.

The VAT Zero-Rating Certificate allows RBEs to claim a zero rating for their sales/purchases from suppliers or vendors.


Contents

Key takeaways

In general, RBEs that meet the 70% threshold for export sales may apply with the Incentives Management Division (IMD) for the issuance of their VAT Zero-Rating Certificate in accordance with the procedure set out under the guidelines.

As an exception, Ecozone Logistics Service Enterprises (ELSEs) must derive 100% of their revenues from transactions with PEZA-registered export enterprises, the Board of Investments, the Clark Development Corporation, Subic Bay Metropolitan Authority-registered export enterprises, and direct-export clients abroad.

The IMD is currently accepting applications for the issuance of VAT Zero Rating Certificates for calendar year 2025.

In detail

The requirements and procedure for the issuance of a VAT Zero-Rating Certificate are provided below. 

A. Requirements

  1. Application form
  2. Copy of payment confirmation for the filing fee
  3. Certificate of notarization stating that (a) at least 70% of the leasable/saleable area is dedicated to export enterprises (for developers/operators and Ecozone Facilities Enterprises) or (b) the required power/volume of water was supplied to export enterprises (for Ecozone Utilities Enterprises)

Export enterprises and ELSEs are not required to submit a notarized certificate, as their export performance can be validated through their respective Ecozone Monthly Performance Reports (EZMPR).

Templates of these requirements (e.g., application form and notarized certificate) are attached to PEZA Memorandum Order No. 2024-007.

B. Procedure

  1. The RBE shall send its application to the IMD via email, together with the documentary requirements in part A above, for pre-processing.
  2. The IMD shall issue an Order of Payment for the payment of the filing fee through the PEZA Electronic Payment and Collection System (EPCS).
  3. The RBE shall pay the filing fee through the PEZA EPCS. PEZA will send payment confirmation to the RBE.
  4. The IMD shall evaluate the application and check for the following:
  • Export Performance Ratio for the preceding calendar year, based on the RBE's submission in the EZMPR (i.e., the RBE must show that it has at least 70% export sales)
  • Outstanding penalties and other financial obligations with other PEZA units (i.e., Support Services Division (SuSD) and Office of the Building Official)

The IMD shall email digitally signed VAT Zero-Rating Certificates to compliant RBEs.

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Ina Alexandra Dominguez
Partner at BakerMcKenzie
Quisumbing Torres, Manila
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ina.dominguez@quisumbingtorres.com
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Associate at BakerMcKenzie
Quisumbing Torres, Manila
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