Kernrechtsfrage
Whether a VAT refund requires payment by the foreign applicant itself rather than by a third party
Extrahierter Entscheid
No. The refund requires that the VAT was economically borne by the applicant; a third-party payment made on the applicant's behalf is sufficient.
Extrahierte Begründung
The term 'paid tax' in the ordinance means the economically borne tax. The refund scheme mirrors input tax deduction; the decisive point is economic burden, not who physically transferred the money. Administrative circulars cannot impose a stricter requirement without a legal basis.