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Question
Global Freight Lines, Inc. (GFL), a Philippine corporation, contracts with TransGlobal Ltd., a foreign company, to provide international freight-forwarding services for shipments from Manila to overseas destinations. The service is performed predominantly by crews aboard GFL’s vessels outside the Philippines. Invoicing is done in Manila and paid in foreign currency. Under the National Internal Revenue Code (NIRC) and the related VAT rules, (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 of services rule from the export-of-services rule and explain how they interact in this case; (c)apply the rules to determine whether GFL’s service qualifies for zero-rated VAT, and justify your conclusion with the governing doctrine and any documentary requirements that the BIR may demand.