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MarinaTech Services, Inc. (MTS), a Philippine corporation, enters into a contract with SeaBright Ltd., a Singapore-based shipping company, to provide port-state-control advisory and vessel-inspection services for SeaBright’s fleet. The services are performed by MTS personnel in Manila; invoices are issued in U.S. dollars and paid into MTS’s Manila bank account. SeaBright uses the service in Singapore. (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 MTS’s service qualifies for zero-rated VAT, and justify with governing doctrine and documentary requirements the BIR may demand.