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Question
ArchiNova Corporation (AN), a Philippine service provider of architectural design and related consultancy, contracts with ArchWorld Pty Ltd, an Australian developer, to provide design and permitting services for a solar farm project in Australia. The services are performed entirely in Manila by AN personnel; AN invoices in USD and deposits payment into AN's Manila bank account. ArchWorld uses the services in Australia. (a)Identify the controlling rule for determining whether the sale of services is taxed in the Philippines or considered an export of services (zero-rated VAT). (b)Distinguish the place-of-supply rule for services from the export-of-services rule and explain how they interact in this scenario. (c)Apply the rules to determine whether AN's service qualifies for zero-rated VAT, and justify with governing doctrine and documentary requirements the BIR may demand.