IT has been more than two years since the promulgation of Republic Act 11534, or the 'Create Act,' but taxpayers are still trying to make sense of the value-added tax (VAT) rules introduced by the said law, particularly those affecting enterprises registered with investment promotion agencies (IPAs). The Bureau of Internal Revenue (BIR) has issued regulations implementing the VAT provisions of the Create Act and a number of circulars to address unclear matters.

Prior to the approval of the law, the VAT system adhered to the 'cross-border doctrine,' wherein no VAT shall form part of the cost of goods destined for consumption outside the territorial border of the taxing authority. As such, purchases of goods and services by ecozone and freeport enterprises were treated as constructive exports subject to zero percent VAT.