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LuminaMed, a Philippine VAT-registered seller of high-precision diagnostic equipment, signs a contract to sell PHP 60,000,000 worth of MRI scanners to Arctic Health AB, a Swedish company. The goods are manufactured in Cebu and delivered to Sweden under DAP terms. The buyer is not VAT-registered in the Philippines. LuminaMed issues an export-sale invoice with 0% VAT and provides export documents (commercial invoice, export declaration, and bill of lading). The goods are actually exported and subsequently imported into Sweden by the buyer.
(a) Identify the governing doctrine(s) that determine the VAT treatment of this cross-border sale, noting which is the primary rule and which is ancillary.
(b) Distinguish the rule on export sales under the destination principle and the documentary requirements for zero-rating, including what happens if export proof is lacking.
(c) Apply the doctrine to the facts: does the sale qualify as a zero-rated export sale? Explain your reasoning and the VAT outcome.