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TechNova Ltd. (TNL), a Philippine corporation, provides software development and ongoing technical support services to GlobeSoft Ltd., a foreign company incorporated in Singapore. The services are performed by TNL personnel in Manila; invoicing is in USD and payment is deposited to TNL’s Manila bank account. GlobeSoft 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 TNL’s service qualifies for zero-rated VAT, and justify with governing doctrine and documentary requirements the BIR may demand.