NINETEENTH CONGRESS OF THE REPUBLIC ) 
OF THE PHILIPPINES 
)
First Regular Session 
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SENATE
Senate Bill No. 1848
»eiwic
ot t!)f i finrj)
23 FEB -7 All :00
Introduced by: Senator Raffy T. Tulfo
AN ACT
AMENDING SECTIONS 6, 22, 24, 25, 27, 28, 32, 34, 37, 38, 39, 42, 51, 52, 
54, 56, 57, 73, 108, 109, 112,121,122, 123, 127, 149,174,176, 179, 181, 
182, 183,184,185, 186, 187,190,195, 198, 199, 204, 222, 237, 237-A, 
255, 256, 257, 258, 261, 263, 264, 266, 275; INSERTING NEW SECTION 
270-A; AND REPEALING SECTIONS 175,177,178, 180,188,192, AND 
193; ALL UNDER REPUBLIC ACT NO. 8424, OTHERWISE KNOWN AS THE 
NATIONAL INTERNAL REVENUE CODE OF 1997, AS AMENDED"
EXPLANATORY NOTE
The Comprehensive Tax Reform Program (CTRP) was established to effectively 
hasten alleviation of poverty and achieve socio-economic equality in our country. As 
part of the Tax reform Package, The proposed bill seeks to create the 4th tax package 
or the Passive Income and Financiai Intermediary Taxation Act (PIFITA).
Since It is imperative that we simplify our tax system enable to achieve full economic 
recovery, the proposed bills seek to reduce the number of final withholding tax rates, 
unify tax rates on passive income, harmonize business taxes on financial


intermediaries, remove the initial public offering (IPO) tax; and Rationaiize 
documentary stamp tax (DST).
In view of the foregoing, the early passage of this bilUs earnestiy sought.
RAFFYT.
Senator


NINETEENTH CONGRESS OF THE REPUBLIC )
OF THE PHILIPPINES 
)
First Regular Session 
)
SENATE
Senate Bill No._ 1848
of tl)f #{ I ftnrp
23 FEB -7 An :00
Rl'CEIVLD BY.
Introduced by: Senator Raffy T. Tulfo
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AN ACT
AMENDING SECTIONS 6, 22, 24, 25, 27, 28, 32, 34, 37, 38, 39, 42, 51, 52, 
54, 56, 57, 73,108, 109, 112,121, 122,123, 127, 149,174, 176,179, 181, 
182,183, 184,185, 186,187,190,195, 198, 199, 204, 222, 237, 237-A, 
255, 256, 257, 258, 261, 263, 264, 266, 275; INSERTING NEW SECTION 
270-A; AND REPEALING SECTIONS 175,177,178, 180,188,192, AND 
193; ALL UNDER REPUBLIC ACT NO. 8424, OTHERWISE KNOWN AS THE 
NATIONAL INTERNAL REVENUE CODE OF 1997, AS AMENDED"
Be it enacted by the Senate and House of Representatives of the Philippines in 
Congress assembled:
SECTION. 1. Title. - This Act shall be known as the "Passive Income and Financial 
Intermediary Taxation Act"
SEC.2. Declaration of Policy. - The financial sector plays a significant role in the long­
term growth of the national economy. A key policy consideration is to allow the capital 
market to develop as efficiently as possible, with the least intervention. The optimal 
taxation of capital markets, and the products and transactions that come with them, 
is an essential element in developing the capital market. Towards this end, the State


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recognizes the necessity of a simpler, fairer, more efficient, and more regionally 
competitive tax system for passive income and financial intermediation to encourage 
savings, develop, as well as deepen the capital markets.
In the same vein, the State recognizes tax administration as a driver of economic 
growth, and the equitable taxation of similar products an essential aspect of the 
progressivity of taxation. By making tax compliance easier and more equitable, 
progressivity is ensured, the tax effort is improved, discretion is eliminated, and thus 
trust in the taxation system is built and enhanced. Accordingly, the State adopts the 
following policies:
1. The State shall promote and develop a tax system that provides neutrality in 
the tax treatment across financial institutions and financial instruments.
2. The State shall endeavor to simplify an otherwise complex tax system for easy 
compliance.
3. The State shall ensure that the taxation of passive income and financial 
transactions is equitable across all stakeholders and discourages arbitrage 
opportunities.
4. The State shall promote capital market development and tax competitiveness 
within the context of globalization, increased capital mobility, and financiai 
inclusion.
5. The State shall endeavor to reform tax administration to improve its efficiency 
and effectiveness and encourage proper and easy compliance by adopting 
international best practices in taxation, modernizing processes, and correcting 
revenue eroding provisions in the National Internal Revenue Code of 1997, as 
amended.
SEC. 3. Section 6 of the NIRC, as amended, is hereby further amended to read as 
follows:
SEC. 6. Power of the Commissioner to Make Assessments and Prescribe 
Additional Requirements for Tax Administration and Enforcement. - 
(A) X X X


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XXX XXX XXX
(F) Authority of the Commissioner to Inquire into AND RECEIVE 
INFORMATION ON [Bank Deposit Accounts] FINANCIAL ACCOUNTS [and 
Other Reiated Information] heid by Financiai Institutions. - Notwithstanding 
any contrary provision of Repubiic Act No. 1405, OTHERWISE KNOWN AS 
THE "BANK SECRECY LAW", Repubiic Act No. 6426, otherwise known as the 
"Foreign Currency Deposit Act," and other generai or speciai iaws, the 
Commissioner is hereby authorized to inquire into AND RECEIVE 
INFORMATION ON FINANCIAL ACCOUNTS INCLUDING [the] bank 
deposits [and other reiated information] heid by financiai institutions of:
(1) X X X 
XXX XXX XXX
(3) A specific taxpayer or taxpayers, UPON AN OBLIGATION TO 
EXCHANGE TAX INFORMATION WITH A FOREIGN TAX AUTHORITY, 
WHETHER ON REQUEST OR AUTOMATIC, [subject of a request for the 
suppiy of tax information from a foreign tax authority] pursuant to an 
internationai convention or agreement on tax matters to which the Phiiippines 
is a signatory or a party of: Provided, That the information obtained from [the 
banks and other] financiai institutions may be used by the Bureau of Internai 
Revenue for tax assessment, verification, audit and enforcement purposes.
[In case of request from a foreign tax authority for tax information heid by 
banks and financiai institutions, the] THE exchange of information WITH A 
FOREIGN TAX AUTHORITY, WHETHER DONE AUTOMATICALLY OR ON 
THE BASIS OF A REQUEST, shaii be done in a secure manner to ensure 
confidentiaiity thereof under such ruies and reguiations [as may be] 
promuigated by the Secretary of Finance, upon recommendation of the 
Commissioner.
IN CASE THE EXCHANGE OF INFORMATION IS UPON REQUEST 
FROM A FOREIGN TAX AUTHORITY, the Commissioner shaii provide the


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tax information obtained from [banks and] financial institutions pursuant to a 
convention or agreement [upon request of such foreign tax authority when 
such requesting foreign tax authority has provided] AND UPON PROVISION 
BY SUCH FOREIGN TAX AUTHORITY OF the following information to 
demonstrate the foreseeable relevance of the information to the request:
(a) X X x;
(b) X X x;
(c) X X x;
(d) X X x;
(e) xxx;
(0 xxx;
(g) X X X
The Commissioner shall forward the information as promptly as possible to the 
requesting foreign tax authority. To ensure a prompt response, the 
Commissioner shall confirm receipt of a request in writing to the requesting tax 
authority and shall notify the latter of deficiencies in the request, if any, within 
sixty (60) days from the receipt of the request.
"If the Commissioner is unable to obtain and provide the information 
within ninety (90) days from the receipt of the request, due to obstacles 
encountered in furnishing the information or when the [bank or] financial 
institution refuses to furnish the information, [he]THE COMMISSIONER shall 
immediately inform the requesting tax authority of the same, explaining the 
nature of the obstacles encountered or the reasons of refusal.
IN CASE OF AUTOMATIC EXCHANGE OF INFORMATION, EVERY 
REPORTING FINANCIAL INSTITUTION SHALL IDENTIFY 
REPORTABLE FINANCIAL ACCOUNTS, ESTABLISH, MAINTAIN AND 
DOCUMENT THE PROCEDURES IT UTILIZED TO IDENTIFY THE SAME, 
KEEP RECORDS OF THE STEPS UNDERTAKEN AND ANY EVIDENCE 
RELIED UPON FOR THE PERFORMANCE OF THE DUE DILIGENCE 
PROCEDURES, PURSUANT TO THE RULES AND REGULATIONS 
PROMULGATED BY THE SECRETARY OF FINANCE, UPON 
RECOMMENDATION OF THE COMMISSIONER, AND IN LINE WITH THE


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"COMMON REPORTING STANDARD" AND ITS COMMENTARY
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PUBLISHED BY THE ORGANISATION FOR ECONOMIC CO-OPERATION
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AND DEVELOPMENT ON 15 JULY 2014, AS AMENDED.
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ALL RECORDS REQUIRED UNDER THIS SECTION OR ITS RULES AND
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REGULATIONS SHALL BE RETAINED AND SAFELY STORED BY
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REPORTING FINANCIAL INSTITUTIONS FOR TEN (10) YEARS FROM
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THE END OF THE YEAR FOLLOWING THE CALENDAR YEAR TO WHICH
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THE RECORDS RELATE.
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FOR THIS PURPOSE, AUTOMATIC EXCHANGE OF INFORMATION
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SHALL REFER TO THE SYSTEMATIC AND PERIODIC TRANSMISSION
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OF INFORMATION CONCERNING VARIOUS CATEGORIES OF INCOME
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OF NONRESIDENT TAXPAYERS TO THEIR COUNTRY OF RESIDENCE.
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The term 'foreign tax authority', as used herein, shall refer to the [tax]
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COMPETENT authority [or tax administration] of the requesting State under
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the tax treaty or convention to which the Philippines is a signatory or a party
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of.
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(4) ANY TAXPAYER UPON ORDER OF ANY COMPETENT COURT IN
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CASES INVOLVING OFFENSES COVERED UNDER SECTION 254 OF
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THIS ACT, AS AMENDED, SUBJECT TO RULES AND REGULATIONS
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PRESCRIBED BY THE SECRETARY OF FINANCE UPON
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RECOMMENDATION OF THE COMMISSIONER OF INTERNAL
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REVENUE.
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"xxx XXX xxx"
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SEC. 4. Section 22 of the National Internal Revenue Code of 1997, as amended, is
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hereby amended to read as follows:
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SEC. 22. Definitions - When used in this Title:
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(A) X X X
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xxx xxx xxx
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(E) The term 'non-resident citizen' means:
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(1) X X X


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XXX XXX XXX
(3) A citizen of the Philippines who works and derives income from abroad and 
whose employment thereat requires [him to be] BEING physically present 
abroad [most of the time] FOR ONE HUNDRED EIGHTY-THREE (183) 
DAYS OR MORE during the taxable year.
(4) A citizen who has been previously considered as A nonresident citizen and 
who arrives in the Philippines at any time during the taxable year to reside 
permanently in the Philippines shall likewise be treated as a nonresident citizen 
for [the taxable] SUCH year [in which he arrives] OF ARRIVAL in the 
Philippines with respect to [his] income derived from sources abroad [until the 
date of his arrival in the Philippines].
(5) A [The] taxpayer shall submit proof to the Commissioner to show [his] 
THE intention of leaving the Philippines to reside permanently abroad or to 
return to and reside in the Philippines, as the case may be for purposes of this 
Section.
xxxxxx
(L) The term 'shares of stock' shall [include] REFER TO shares of stock of a 
corporation, warrants and/or options [to purchase shares of stock], WHETHER 
TO BUY OR SELL SECURITIES, AND FUTURES CONTRACTS, LISTED 
AND TRADED IN AN EXCHANGE OR AN ORGANIZED MARKETPLACE,
as well as units of participation in a partnership (except general professional 
partnerships), joint stock companies, joint accounts, COLLECTIVE 
INVESTMENT SCHEMES, joint ventures taxable as corporations, 
associations, and recreation or amusement clubs (such as golf, polo or similar 
clubs), and mutual fund certificates.
(M) The term 'shareholder' shall [include] REFER TO holders of a share/s of 
stock, warrant/s and/or option/s [to purchase shares of stock of a corporation],
WHETHER TO BUY OR SELL SECURITIES AND FUTURES CONTRACTS,


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LISTED AND TRADED IN AN EXCHANGE OR AN ORGANIZED 
MARKETPLACE, as well as a holder of a unit of participation in a partnership 
(except general professional partnerships), in a joint stock company, a joint 
account, A COLLECTIVE INVESTMENT SCHEME, a taxable joint venture, a 
member of an association, recreation or amusement club [Qsuch as golf, polo, 
or similar clubs[)], and a holder of a mutual fund certificate, a member in an 
association, joint-stock company, or insurance company.
XXX XXX XXX
(T) The term 'securities' [means shares of stock in a corporation and rights to 
subscribe for or to receive such shares. The term includes bonds, debentures, 
notes or certificates, or other evidence of indebtedness, issued by any 
corporation, including those issued by a government or political subdivision 
thereof, with interest coupons or in registered form.] SHALL REFER TO 
SHARES, PARTICIPATION OR INTERESTS IN A CORPORATION OR IN 
A COMMERCIAL ENTERPRISE OR PROFIT-MAKING VENTURE 
EVIDENCED BY A CERTIFICATE, CONTRACT, INSTRUMENTS, 
WHETHER WRITTEN OR ELECTRONIC IN CHARACTER. THESE 
INCLUDE:
(1) 
SHARES OF STOCK, BONDS, DEBENTURES, NOTES, 
EVIDENCES OF INDEBTEDNESS, AND ASSET-BACKED SECURITIES;
(2) 
INVESTMENT CONTRACTS, CERTIFICATES OF INTEREST, OR 
PARTICIPATION IN A PROFIT-SHARING AGREEMENT SUCH AS 
COLLECTIVE INVESTMENT SCHEMES, OR CERTIFICATE OF DEPOSIT 
FOR A FUTURE SUBSCRIPTION;
(3) 
FRACTIONAL UNDIVIDED INTERESTS IN OIL, GAS, OR OTHER 
MINERAL RIGHTS;
(4) 
CERTIFICATES OF ASSIGNMENTS, CERTIFICATES OF 
PARTICIPATION, TRUST CERTIFICATES, VOTING TRUST 
CERTIFICATES, OR SIMILAR INSTRUMENTS;


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(5) 
PROPRIETARY OR NON-PROPRIETARY MEMBERSHIP 
CERTIFICATES IN CORPORATIONS; AND
(6) 
OTHER INSTRUMENTS AS MAY BE DETERMINED BY THE 
SECURITIES AND EXCHANGE COMMISSION.
Xxx XXX XXX
(V) The term ['bank'] "BANKS" [means every banking institution, as defined 
in Section 2 Republic Act No. 337, as amended, otherwise known as the 
"General Banking Act." A bank may either be, a commercial bank, a thrift bank, 
a development bank, a rural bank or specialized government bank] SHALL 
REFER TO ENTITIES ENGAGED IN THE LENDING OF FUNDS OBTAINED 
IN THE FORM OF DEPOSITS AS DEFINED AND CLASSIFIED IN 
SECTION 3 OF REPUBLIC ACT NO. 8791, OTHERWISE KNOWN AS THE 
"GENERAL BANKING LAW OF 2000."
(W) The term 'non-bank financial intermediary' [means a financial intermediary, 
as defined in Section 2(D)(C) of Republic Act No. 337, as amended, otherwise 
known as the "General Banking Act," authorized by the Bangko Sentral ng 
Pilipinas (BSP) to perform quasi-banking activities] SHALL REFER TO 
PERSONS OR ENTITIES ENGAGED IN THE BORROWING OF FUNDS, 
FOR THE BORROWER'S OWN ACCOUNT, THROUGH THE ISSUANCE, 
ENDORSEMENT, OR ACCEPTANCE OF DEBT INSTRUMENTS OF 
ANYKIND OTHER THAN DEPOSITS, OR THROUGH THE ISSUANCE 
OF, CERTIFICATES OF ASSIGNMENT, OR SIMILAR INSTRUMENTS 
WITH RECOURSE, TRUST CERTIFICATES, OR OF REPURCHASE 
AGREEMENTS FROM TWENTY (20) OR MORE LENDERS AT ANY GIVEN 
TIME, FOR PURPOSES OF RELENDING OR PURCHASING OF 
RECEIVABLES AND OTHER OBLIGATIONS, BUT DOES NOT INCLUDE 
COMMERCIAL, INDUSTRIAL, AND OTHER NON- 
FINANCIALCOMPANIES WHICH BORROW FUNDS THROUGH ANY OF 
THESE MEANS FOR THE LIMITED PURPOSE OF FINANCING THEIR 
OWN NEEDS OR THE NEEDS OF THEIR AGENTS OR DEALERS.
(X) THE TERM 'QUASI-BANK' SHALL REFER TO A NON-BANK 
FINANCIAL INSTITUTION AUTHORIZED BY THE BANGKO SENTRAL
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NG PILIPINAS TO ENGAGE IN QUASI-BANKING FUNCTIONS AND TO 
BORROW FUNDS FROM MORE THAN NINETEEN (19) LENDERS 
THROUGH THE ISSUANCE, ENDORSEMENT OR ASSIGNMENT WITH 
RECOURSE OR ACCEPTANCE OF DEPOSIT SUBSTITUTES FOR 
PURPOSES OF RELENDING OR PURCHASING OF RECEIVABLES 
AN DOTH ER OBLIGATIONS.
[(X)] (Y) The term 'quasi-banking activities' [means] SHALL REFER TO 
borrowing OF funds from twenty (20) or more [personai] INDIVIDUALS or 
corporate lenders at any [one time] GIVEN TIME through the issuance, 
endorsement, or acceptance of debt instruments of any kind other than 
deposits for the borrower's own account, or through the issuance of certificates 
of assignment or similar instruments, with recourse, or of repurchase 
agreements for purposes of relending or purchasing receivables and other 
similar obligations; Provided, however, That commercial, industrial, and other 
non-financial companies[,] which borrow funds through any of these means for 
the limited purpose of financing their own needs or the needs of their agents 
or dealers, shall not be considered as ENTITIES performing quasi-banking 
functions.
[(Y)] (Z) The term 'deposit substitutes' shall [mean] REFER TO an alternative 
form of obtaining funds from the public [(the term 'public' means borrowing 
from twenty (20) or more individual or corporate lenders at any one time)] 
other than deposits, through the issuance, endorsement, or acceptance of debt 
instruments for the borrowers own account, for the purpose of relending or 
purchasing of receivables and other obligations[, or financing their own needs 
or the needs of their agent or dealer.]: PROVIDED, THAT THE TERM 
"PUBLIC" SHALL MEAN TWENTY (20) OR MORE INDIVIDUAL OR 
COPRORATE LENDERS AT ANY ONE TIME. These instruments may include, 
but need not be limited to bankers' acceptances, promissory notes, repurchase 
agreements, [including] EXCLUDING reverse repurchase agreements entered 
into by and between the Bangko Sentral ng Pilipinas (BSP) and any authorized 
agent bank, certificates of assignment or participation and similar instruments 
with recourse[.]; PROVIDED FURTHER, THAT DEBT INSTRUMENTS


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ISSUED BY THE GOVERNMENT AND ANY OF ITS AGENCIES AND 
INSTRUMENTALITIES INCLUDING GOVERNMENT FINANCIAL 
INSTITUTIONS, SHALL BE DEEMED ISSUED TO THE PUBLIC AND 
CONSIDERED DEPOSIT SUBSTITUTES: PROVIDED, FURTHERMORE, 
THAT IF THE INTENTION IS FOR THE DEBT INSTRUMENTS TO BE 
HELD BY MORE THAN NINETEEN (19) HOLDERS DURING THE TERM 
OF THE DEBT INSTRUMENT OR IF THE TENOR AND DENOMINATION 
ARE SUCH THAT THEY CAN BE HELD BY MORE THAN NINETEEN (19) 
LENDERS, THEN THE INSTRUMENT SHALL BE CONSIDERED DEPOSIT 
SUBSTITUTES; Provided however, That debt instruments issued for interbank 
call loans with maturity of not more than five (5) days to cover deficiency in 
reserves against deposit liabilities, including those between or among banks 
and quasi-banks, shall not be considered as deposit substitute debt 
instruments.
[(Z)] (AA) The term 'ordinary income' xxx xxx xxx 
[(AA)] (BB) The term 'rank and file employees' xxx xxx xxx 
[(BB)] (CC) The term 'mutual fund company' xxx xxx xxx
[(CC)] (DD) The term 'trade, business or profession' xxx xxx xxx 
[(DD)] (EE) The term 'regional or area headquarters' xxx xxx xxx 
[(EE)] (FF) The term 'regional operating headquarters' xxx xxx xxx 
[(FF)] (GG) The term 'long-term deposit or investment certificate' xxx xxx xxx
[(GG)1 (HH) The term 'statutory minimum wage' xxx xxx xxx 
[(HH)] (II) The term 'minimum wage earner' xxx xxx xxx 
[(H)] (33) The term 'offshore gaming licensee' xxx xxx xxx 
[QJ)] (KK) The term 'offshore gaming licensee-gaming agent' xxx xxx
(LL) THE TERM 'COLLECTIVE INVESTMENT SCHEMES' OR 'CIS' SHALL 
REFER TO ANY ARRANGEMENT WHEREBY FUNDS ARE SOLICITED 
FROM THE INVESTING PUBLIC AND POOLED TOGETHER FOR THE
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PURPOSE OF INVESTING, RE-INVESTING, OR TRADING IN 
SECURITIES OR OTHER ASSETS OR DIFFERENT CLASSES THEREOF AS 
ALLOWED UNDER THE LAW, WHICH MAY EITHER HAVE A 
CORPORATE STRUCTURE, SUCH AS AN INVESTMENT COMPANY, OR A 
CONTRACTUAL STRUCTURE, SUCH AS A UNIT INVESTMENT TRUST 
FUND OR SIMILAR SCHEME HELD BY A TRUST CORPORATION OR A 
SEPARATE ACCOUNT FUND ESTABLISHED PURSUANT TO A VARIABLE 
UNIT LINKED LIFE INSURANCE POLICY ISSUED BY AN INSURANCE 
COMPANY, AND SUCH OTHER FORMS OF COLLECTIVE INVESTMENT 
SCHEMES AS MAY BE DETERMINED BY THE BUREAU OF INTERNAL 
REVENUE IN CONSULTATION WITH APPROPRIATE GOVERNMENT 
REGULATORY AGENCIES SUCH AS THE BANGKO SENTRAL NG 
PILIPINAS, THE SECURITIES AND EXCHANGE COMMISSION AND THE 
INSURANCE COMMISSION. A CIS MAY EITHER BE OPEN-ENDED OR 
CLOSED-ENDED, DEFINED AS FOLLOWS:
'OPEN-ENDED CIS' SHALL REFER TO A CIS WHERE SECURITIES ARE 
OFFERED AND ARE ALWAYS REDEEMABLE BY THE CIS; AND
'CLOSED-ENDED CIS' SHALL REFER TO A CIS WHERE A FIXED 
NUMBER OF SECURITIES ARE OFFERED IN AN INITIAL PUBLIC 
OFFERING AND THEREAFTER MAY BE TRADED IN AN ORGANIZED 
MARKET PLACE AS DETERMINED BY THE SECURITIES AND 
EXCHANGE COMMISSION, BUT MAY NOT BE REDEEMED BY THE CIS. 
A CLOSED-ENDED CIS SHALL NOT BE ALLOWED TO INCREASE ITS 
NUMBER OF SECURITIES.
(MM) THE TERM 'ORGANIZED MARKETPLACE' SHALL REFER TO AN 
EXCHANGE, AN OVER-THE-COUNTER MARKET, OR AN ALTERNATIVE 
TRADING SYSTEM RECOGNIZED AS SUCH BY THE SECURITIES AND 
EXCHANGE COMMISSION AS AN EXCHANGE UNDER REPUBLIC ACT 
NO. 8799, OTHERWISE KNOWN AS THE "SECURITIES REGULATION
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CODE", AS AMENDED, AND GOVERNED BY, AMONG OTHERS, 
TRANSPARENT AND BINDING RULES AND MARKET CONVENTIONS 
ON MEMBERSHIP, TRADING, PRICE TRANSPARENCY, TRADE 
REPORTING, MARKET MONITORING AND ORDERLY CONDUCT OF 
THE MARKET WHICH ARE ENFORCEABLE ON THE MEMBERS AND 
PARTICIPANTS.
(NN) THE TERM 'HEALTH INSURANCE PRODUCTS' SHALL REFER TO 
THOSE THAT ARE BEING OFFERED AND SOLD BY INSURANCE 
COMPANIES, EITHER LIFE OR NON-LIFE, WHEREIN THERE IS A LIST 
OF COVERED ILLNESSES OF WHICH THE COMPANIES ASSUME RISKS 
AND INDEMNIFY LOSSES BROUGHT BY THE SAID COVERED 
ILLNESSES.
(00) THE TERM 'HEALTH MAINTENANCE ORGANIZATION PRODUCTS' 
SHALL REFER TO PRE-AGREED OR DESIGNATED HEALTH CARE 
SERVICES TO THE ENROLLED MEMBERS FOR A FIXED PRE-PAID FEE 
FOR A SPECIFIED PERIOD OF TIME THROUGH THE USE OF SELECTED 
NETWORK OF HEALTH CARE PROVIDERS. HEALTH MAINTENANCE 
ORGANIZATION (HMO) PRODUCTS PROVIDE A WIDE ARRAY OF 
MEDICAL, SURGICAL AND HOSPITAL SERVICES THAT INCLUDE 
PREVENTIVE CARE AND WELLNESS PROGRAMS AND GENERALLY 
HAVE NO CASH-OUT TRANSACTIONS."
SEC. 5. Section 24 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
"SEC. 24. Income Tax Rates. -
(A) Rates of Income Tax on Individual Citizen and Individual Resident Alien of 
the Philippines. -
XXX XXX XXX
(B) [Rate] RATES of Tax on Certain Passive Income: -
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(1) Interests[, Royalties, Prizes, and Other Winnings.] - A final tax [at the rate 
of twenty percent (20%)] is hereby imposed upon the amount of interest [from 
any currency bank deposit, and yield or any other monetary benefit from 
deposit substitutes, and from trust funds and similar arrangements; royalties, 
except on books, as well as other literary works and musical compositions, 
which shall be imposed a final tax of ten percent (10%); prizes (except prizes 
amounting to Ten thousand pesos (P10,000) or less which shall be subject to 
tax under Subsection (A) of Section 24; and other winnings (except winnings 
amounting to Ten Thousand pesos (P10,000) or less from Philippine Charity 
Sweepstakes and Lotto which shall be exempt), derived from sources within 
the Philippines:] YIELD, OR ANY OTHER MONETARY BENEFIT EARNED 
OR RECEIVED FROM ANY CURRENCY BANK DEPOSIT, DEPOSIT 
SUBSTITUTE, TRUST FUND, AND SIMILAR ARRANGEMENTS.
[Provided, however. That interest income received by an individual taxpayer 
(except a non-resident individual) from a depository bank under the expanded 
foreign currency deposit system shall be subject to a final income tax at the 
rate of fifteen percent (15%) of such interest income: Provided, further. That 
interest income from long-term deposit or investment in the form of savings, 
common or individual trust funds, deposit substitutes, investment management 
accounts and other investments evidenced by certificates in such form 
prescribed by the Bangko Sentral ng Pilipinas (BSP) shall be exempt from the 
tax imposed under this Subsection: Provided, finally. That should the holder of 
the certificate pre-terminate the deposit or investment before the fifth (5th) 
year, a final tax shall be imposed on the entire income and shall be deducted 
and withheld by the depository bank from the proceeds of the long-term deposit 
or investment certificate based on the remaining maturity thereof:]
[Four (4) years to less than five (5) years - 5%;]
[Three (3) years to less than (4) years - 12%; and]
[Less than three (3) years - 20%.]
(2) Cash and/or Property Dividends. - A final tax at the rate of [ten percent 
(10%)] FIFTEEN PERCENT (15%) shall be imposed upon the cash and/or
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property dividends actually or constructively received by an individual from a 
domestic corporation or from a joint stock company, insurance or mutual fund 
companies, AND ENTITIES ENGAGED IN COLLECTIVE INVESTMENT 
SCHEMES, [and regional operating headquarters of multinational companies], 
or on the share of an individual in the distributable net income after tax of a 
partnership, [Qexcepta general professional partnership^] of which [he] THE 
INDIVIDUAL is a partner, or on the share of an individual in the net income 
after tax of an association, a joint account, or a joint venture or consortium 
taxable as a corporation of which [he] THE INDIVIDUAL is a member or co­
venturer: PROVIDED, HOWEVER, THAT THE APPLICABLE TAX RATE ON 
DIVIDENDS SHALL APPLY ONLY ON INCOME EARNED ON OR AFTER 
JANUARY 1, 2023. INCOME FORMING PART OF RETAINED EARNINGS 
AS OF DECEMBER 31, 2022, EVEN IF DECLARED OR DISTRIBUTED ON 
OR AFTER JANUARY 1, 2023, SHALL BE SUBJECT TO TEN PERCENT 
(10%) TAX.
[(C)](3) Capital Gains from THE Sale, EXCHANGE, BARTER, OR 
DISPOSITION of Shares of Stock not Traded in the Stock Exchange OR 
ORGANIZED MARKETPLACE. - [The provisions of Section 39(B) 
notwithstanding, a] A final tax at the rate of fifteen percent (15%) is hereby 
imposed upon the net capital gains realized during the taxable year from the 
sale, barter, exchange or other disposition of shares of stock in a domestic 
corporation, except shares sold, or disposed of through A LOCAL [the] stock 
exchange[.] OR AN ORGANIZED MARKETPLACE.
[(D)](4) Capital Gains from Sale of Real Property. - 
[(1)] (a) In General. - [The provisions of Section 39(B) notwithstanding, a] A 
final tax of six percent (6%) based on the gross selling price or current fair 
market value as determined in accordance with Section 6(E) of this Code, 
whichever is higher, is hereby imposed upon capital gains presumed to have 
been realized from the sale, exchange, or other disposition of real property 
located in the Philippines, classified as capital assets, including pacto de retro
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sales and other forms of conditional sales, by individuals, including estates and 
trusts: Provided, That the tax liability, if any, on gains from sales or other 
dispositions of real property to the government or any of its political 
subdivisions or agencies or to government-owned or controlled corporations 
shall be determined either under Section 24(A) or under this Subsection, at the 
option of the taxpayer.
[(2)] (b) Exception. - xxx xxx xxx
(5) ROYALTIES, PRIZES, AND OTHER WINNINGS. - A FINAL TAX IS 
HEREBY IMPOSED ON ROYALTIES EARNED AS PASSIVE INCOME, 
PRIZES, AND OTHER WINNINGS, ACCORDING TO THE FOLLOWING 
SCHEDULE:
EFFECnVITY
TAX RATE ON ROYALTIES,
PRIZES, AND OTHER WINNINGS
JANUARY 1, 2023
NINETEEN PERCENT (19%)
JANUARY 1, 2024
EIGHTEEN PERCENT (18%)
JANUARY 1, 2025
SEVENTEEN PERCENT (17%)
JANUARY 1, 2026
SIXTEEN PERCENT (16%)
JANUARY 1, 2027
FIFTEEN PERCENT (15%)
PROVIDED, THAT ROYALTIES FROM BOOKS, AS WELL AS OTHER LITERARY 
WORKS AND MUSICAL COMPOSITIONS, SHALL BE SUBJECT TO A FINAL TAX 
OF TEN PERCENT (10%) OF SUCH ROYALTIES: PROVIDED FURTHER, THAT 
PRIZES AMOUNTING TO TEN THOUSAND PESOS (P10,000) OR LESS SHALL 
BE SUBJECT TO TAX UNDER SECTION 24(A): PROVIDED FURTHERMORE, 
THAT PHILIPPINE CHARITY SWEEPSTAKES AND LOTTO WINNINGS NOT 
EXCEEDING TEN THOUSAND PESOS (P10,000) SHALL BE EXEMPT: 
PROVIDED FINALLY, THAT PHILIPPINE CHARITY SWEEPSTAKES AND 
LOTTO WINNINGS EXCEEDING TEN THOUSAND PESOS (P10,000) SHALL BE 
SUBJECT TO A FINAL TAX OF TEN PERCENT (10%) OF SUCH WINNINGS."
15


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SEC. 6. Section 25 of the National Internal Revenue Code of 1997, as amended, is
2 
hereby amended to read as follows:
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"SEC. 25. Tax on Nonresident Alien Individual. -
5 
(A) Nonresident Alien Engaged in Trade or Business Within the Philippines. [(1)
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In General. -]A nonresident alien individual engaged in trade or business in
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the Philippines shall be subject to [an] income tax UNDER SECTION 24 OF
8 
THIS CODE[/ in the same manner as an individual citizen and a resident alien
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individual,] on taxable income received from all sources within the Philippines.
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A nonresident alien individual who shall come to the Philippines and stay therein
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for an aggregate period of more than [one hundred eighty (180)] ONE
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HUNDRED EIGHTY-THREE (183) days during any calendar year shall be
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deemed a 'nonresident alien doing business in the Philippines^.], Section 22(G)
14 
of this Code notwithstanding.
15 
[(2) Cash and/or Property Dividends from a Domestic Corporation or Joint Stock
16 
Company, or Insurance or Mutual Fund Company or Regional Operating
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Headquarter or Multinational Company, or Share in the Distributable Net
18 
Income of a Partnership (Except a General Professional Partnership), Joint
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Account, Joint Venture Taxable as a Corporation or Association, Interests,
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Royalties, Prizes, and Other Winnings. - Cash and/or property dividends from
21 
a domestic corporation, or from a joint stock company, or from an insurance or
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mutual fund company or from a regional operating headquarter of multinational
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company, or the share of a nonresident alien individual in the distributable net
24 
income after tax of a partnership (except a general professional partnership)
25 
of which he is a partner, or the share of a nonresident alien individual in the
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net income after tax of an association, a joint account, or a joint venture taxable
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as a corporation of which he is a member or a co-venturer; interests; royalties
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(in any form); and prizes (except prizes amounting to Ten thousand pesos
29 
(P10,000.00) or less which shall be subject to tax under Subsection (B)(1) of
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Section 24); and other winnings (except winnings amounting to ten thousand
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pesos (P10,000.00) or less from Philippine Charity Sweepstakes Office (PCSO)
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games which shall be exempt); shall be subject to an income tax of twenty
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percent (20%) on the total amount thereof: Provided, however, That royalties 
on books as well as other literary works, and royalties on musical compositions 
shall be subject to a final tax of ten percent (10%) on the total amount thereof: 
Provided, further. That cinematographic films and similar works shall be subject 
to the tax provided under Section 28 of this Code: Provided, furthermore. That 
interest income from iong-term deposit or investment in the form of savings, 
common or individual trust funds, deposit substitutes, investment management 
accounts and other investments evidenced by certificates in such form 
prescribed by the Bangko Sentral ng Pilipinas (BSP) shall be exempt from the 
tax imposed under this Subsection: Provided, finally. That should the holder of 
the certificate pre-terminate the deposit or investment before the fifth (5th) 
year, a final tax shall be imposed on the entire income and shall be deducted 
and withheld by the depository bank from the proceeds of the iong-term deposit 
or investment certificate based on the remaining maturity thereof:]
[Four (4) years to less than five (5) years - 5%;]
[Three (3) years to less than four (4) years - 12%; and]
[Less than three (3) years - 20%.]
[(3) Capital Gains. - Capital gains realized from sale, barter or exchange of 
shares of stock in domestic corporations not traded through the local stock 
exchange, and real properties shail be subject to the tax prescribed under 
Subsections (C) and (D) of Section 24.]
(B) Nonresident Alien Individual Not Engaged in Trade or Business Within the 
Philippines. - There shaii be levied, coiiected and paid for each taxabie year 
upon the entire income received from all sources within the Philippines by every 
nonresident alien individual not engaged in trade or business within the 
Philippines SUCH as [interest, cash and/or property dividends,] rents, salaries, 
wages, premiums, annuities, compensation, remuneration, emoluments, or 
other fixed or determinable annual or periodic or casual gains, profits, and 
income, [and capital gains, ]a FINAL tax equal to twenty five percent (25%) of 
such income. Capital gains realized by a nonresident alien individual not 
engaged in trade or business in the Philippines from the sale of [shares of stock
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in any domestic corporation and] real property shall be subject to the income 
tax prescribed under Subsection[s (C) and (D)] (B) (4) of Section 24.
INTEREST, DIVIDENDS AND CAPITAL GAINS ON SALE, BARTER 
EXCHANGE OR OTHER DISPOSTION OF SHARES OF STOCK, SHALL BE 
SUBJECT TO THE APPLICABLE TAXES PRESCRIBED UNDER SECTION 
24(B), OR TO THE PROVISIONS OF THE APPLICABLE TAX TREATY.
XXX XXX
XXX
SEC. 7. Section 27 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
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"SEC. 27. Rates of Income Tax on Domestic Corporations. - 
(A) In General, -xxx 
XXX xxx xxx
(D) Rates of Tax on Certain Passive Incomes.
[(1) Interest from Deposits and Yield or any other Monetary Benefit from 
Deposit Substitutes and from Trust Funds and Similar Arrangements, and 
Royalties. - A final tax at the rate of twenty percent (20%) is hereby imposed 
upon the amount of interest on currency bank deposit and yield or any other 
monetary benefit from deposit substitutes and from trust funds and similar 
arrangements received by domestic corporations, and royalties, derived from 
sources within the Philippines; Provided, however. That interest income derived 
by a domestic corporation from a depository bank under the expanded foreign 
currency deposit system shall be subject to a final income tax at the rate of 
fifteen percent (15%) of such interest income.]
[(2) Capital Gains from the Sale of Shares of Stock Not Traded in the Stock 
Exchange. - A final tax at the rate of fifteen percent (15%) shall be imposed 
on net capital gains realized during the taxable year from the sale, 
exchange or other disposition of shares of stock in a domestic corporation 
except shares sold or disposed of through the stock exchange.]
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[(3) Tax on Income Derived under the Expanded Foreign Currency Deposit 
System. - Income derived by a depository bank under the expanded foreign 
currency deposit system from foreign currency transactions with nonresidents, 
offshore banking units in the Philippines, local commercial banks including 
branches of foreign banks that may be authorized by the Bangko Sentral ng 
Pilipinas (BSP) to transact business with foreign currency deposit system shall 
be exempt from all taxes, except net income from such transactions as may be 
specified by the Secretary of Finance, upon recommendation by the Monetary 
Board to be subject to the regular income tax payable by banks: Provided, 
however. That interest income from foreign currency loans granted by such 
depository banks under said expanded system to residents other than offshore 
banking units in the Philippines or other depository banks under the expanded 
system, shall be subject to a final tax at the rate of ten percent (10%).]
[Any income of nonresidents, whether individuals or corporations, from 
transactions with depository banks under the expanded system shall be exempt 
from income tax.]
(1) INTERESTS. - A FINAL TAX OF TWENTY PERCENT (20%) IS 
HEREBY IMPOSED UPON THE AMOUNT OF INTEREST, YIELD, OR 
OTHER MONETARY BENEFIT EARNED OR RECEIVED FROM ANY 
CURRENCY BANK DEPOSIT, DEPOSIT SUBSTITUTE, TRUST FUND, 
AND SIMILAR ARRANGEMENTS.
[(4)](2) Intercorporate Dividends. - x x x
(3) CAPITAL GAINS FROM THE SALE, EXCHANGE, BARTER OR 
DISPOSITION OF SHARES OF STOCK NOT TRADED IN THE STOCK 
EXCHANGE OR AN ORGANIZED MARKETPLACE - A FINAL TAX AT THE 
RATE OF FIFTEEN PERCENT (15%) IS HEREBY IMPOSED UPON THE 
NET CAPITAL GAINS REALIZED DURING THE TAXABLE YEAR FROM 
THE SALE, BARTER, EXCHANGE, OR OTHER MODES OF DISPOSITION 
OF SHARES OF STOCK OF A DOMESTIC CORPORATION, EXCEPT
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SHARES SOLD, OR DISPOSED OF THROUGH A LOCAL STOCK 
EXCHANGE OR AN ORGANIZED MARKETPLACE.
[(5)](4) Capital Gains Realized from the Sale, Exchange or Disposition of Lands 
and/or Buildings. - A final tax of six percent (6%) is hereby imposed on the 
gain presumed to have been realized on the sale, exchange or disposition of 
lands and/or buildings which are not actually used in the business of a 
corporation and are treated as capital assets, based on the gross selling price 
or fair market value as determined in accordance with Section 6(E) of this Code, 
whichever is higher, of such lands and/or buildings.
[(E)](5) ROYALTIES - A FINAL TAX IS HEREBY IMPOSED ON 
ROYALTIES EARNED AS PASSIVE INCOME ACCORDING TO THE 
FOLLOWING SCHEDULE:
EFFECTIVITY
TAX RATE ON ROYALTIES
JANUARY 1, 2023
NINETEEN PERCENT (19%)
JANUARY 1, 2024
EIGHTEEN PERCENT (18%)
JANUARY 1, 2025
SEVENTEEN PERCENT (17%)
JANUARY 1, 2026
SIXTEEN PERCENT (16%)
JANUARY 1, 2027
FIFTEEN PERCENT (15%)
(E) Minimum Corporate Income Tax on Domestic Corporations -
(1) Imposition of Tax. - x x x
(2) Carry forward of Excess Minimum Tax. - x x x
(3) Relief from the Minimum Corporate Income Tax under Certain Conditions.
- X X X
(4) Gross Income Defined. - x x x
XXX XXX XXX
In the case of taxpayers engaged in the sale of service, 'gross income' means 
gross receipts less sales returns, allowances, discounts and cost of services. 
'Cost of services' shall mean all direct costs and expenses necessarily incurred
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to provide the services required by the customers and clients including (A) 
salaries and employee benefits of personnel, consultants and specialists directly 
rendering the service and (B) cost of facilities directly utilized in providing the 
service such as depreciation or rental of equipment used and cost of supplies: 
Provided, however. That in the case of banks AND OTHER FINANCIAL 
INTERMEDIARIES, 'cost of services' shall include interest expense.
XXX XXX XXX
SEC. 8. Section 28 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
"SEC. 28. Rates of Income Tax on Foreign Corporations. - x x x
(A) Tax on Resident Foreign Corporations. - x x x
(1) In General. - x x x
XXX XXX 
XXX
INTEREST, INTERCORPORATE DIVIDENDS, CAPITAL GAINS ON SALE, 
BARTER, EXCHANGE, OR OTHER DISPOSITION OF SHARES OF STOCK 
NOT TRADED IN THE STOCK EXCHANGE OR AN ORGANIZED MARKET 
PLACE, AND ROYALTIES SHALL BE SUBJECT TO THE APPLICABLE 
TAXES PRESCRIBED UNDER SECTION 27(D) OF THIS CODE.
(2) Minimum Corporate Income Tax on Resident Foreign Corporations. - x x x
(3) International Carrier - x x x
(4) Tax on Branch Profits Remittances. - Any profit remitted by a branch to its 
head office shall be subject to a tax of fifteen percent (15%) which shall be 
based on the total profits applied or earmarked for remittance without any 
deduction for the tax component thereof [(except those activities which are 
registered with the Philippine Economic Zone Authority)]. The tax shall be 
collected and paid in the same manner as provided in Sections 57 and 58 of
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this Code: Provided, That interests, dividends, rents, royalties, including 
remuneration for technical services, salaries, wages, premiums, annuities, 
emoluments or other fixed or determinable annual, periodic or casual gains, 
profits, income and capital gains received by a foreign corporation during each 
taxable year from all sources within the Philippines shall not be treated as 
branch profits unless the same are effectively connected with the conduct of 
its trade or business in the Philippines.
(5) Regional or Area Headquarters and Regional Operating Headquarters of 
Multinational Companies. - x x x
[(6) Tax on Certain Incomes Received by a Resident Foreign Corporation. - ] 
[(a) Interest from Deposits and Yield or any other Monetary Benefit from 
Deposit Substitutes, Trust Funds and Similar Arrangements and Royalties. - 
Interest from any currency bank deposit and yield or any other monetary 
benefit from deposit substitutes and from trust funds and similar arrangements 
and royalties derived from sources within the Philippines shall be subject to a 
final income tax at the rate of twenty percent (20%) of such interest: Provided, 
however. That interest income derived by a resident foreign corporation from 
a depository bank under the expanded foreign currency deposit system shall 
be subject to a final income tax at the rate of fifteen percent (15%) of such 
interest income.]
[(b) Income Derived under the Expanded Foreign Currency Deposit System. - 
Income derived by a depository bank under the expanded foreign currency 
deposit system from foreign currency transactions with nonresidents, offshore 
banking units in the Philippines, local commercial banks including branches of 
foreign banks that may be authorized by the Bangko Sentral ng Pilipinas (BSP) 
to transact business with foreign currency deposit system units, and other 
depository banks under the expanded foreign currency deposit system shall be 
exempt from all taxes, except net income from such transactions as may be 
specified by the Secretary of Finance, upon recommendation by the Monetary 
Board to be subject to the regular income tax payable by banks: Provided 
however. That interest income from foreign currency loans granted by such 
depository banks under said expanded system to residents other than offshore
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banking units in the Philippines or other depository banks under the expanded 
system shall be subject to a final tax at the rate of ten percent (10%).]
[Any income of nonresidents, whether individuals or corporations, from 
transactions with depository banks under the expanded system shall be exempt 
from income tax.]
[(c) Capital Gains from Sale of Shares of Stock Not Traded in the Stock 
Exchange. - A final tax at the rate of fifteen percent (15%) is hereby imposed 
upon the net capital gains realized during the taxable year from the sale, barter, 
exchange or other disposition of shares of stock in a domestic corporation 
except shares sold or disposed of through the stock exchange.]
[(d) Intercorporate Dividends. - Dividends received by a resident foreign 
corporation from a domestic corporation liable to tax under this Code shall not 
be subject to tax under this Title.]
[(7)](6) Offshore Gaming Licensees. - x x x 
(B) Tax on Nonresident Foreign Corporation. -
(1) In General. - Except as otherwise provided in this Code, a foreign 
corporation not engaged in trade or business in the Philippines, effective 
January 1, 2021, shall pay a tax equal to twenty- five percent (25%) of the 
gross income received during each taxable year from all sources within the 
Philippines, such as [interests, dividends,] rents, [royalties,] salaries, 
premiums, [(]except reinsurance premiums[)], annuities, emoluments or other 
fixed or determinable annual, periodic or casual gains, profits and income, and 
capital gains, except capital gains subject to tax under subparagraph 5(A)[(c)].
XX XXX XXX
(5) Tax on Certain Incomes Received by a Nonresident Foreign Corporation, 
[(a) Interest on Foreign Loans. - A final withholding tax at the rate of twenty 
percent (20%) is hereby imposed on the amount of interest on foreign loans 
contracted on or after August 1, 1986;]
(A) INTERESTS AND CAPITAL GAINS ON SALE, BARTER, EXCHANGE, 
OR OTHER FORMS OF DISPOSITION OF SHARES OF STOCK NOT 
TRADED IN THE STOCK EXCHANGE OR AN ORGANIZED MARKET 
PLACE, AND ON ROYALTIES SHALL BE SUBJECT TO THE APPLICABLE
23


1 
TAXES UNDER SECTION 27(D) OF THIS CODE, 
OR TO THE
2 
PROVISIONS OF THE APPLICABLE TAX TREATY.
3 
(b) Intercorporate Dividends. - A final withholding tax at the rate of fifteen
4 
percent (15%) is hereby imposed on the amount of cash and/or property
5 
dividends received from a domestic corporation, which shall be collected and
6 
paid as provided in Section 57(A) of this Code, subject to the condition that the
7 
country in which the nonresident foreign corporation is domiciled, shall allow a
8 
credit against the tax due from the nonresident foreign corporation taxes
9 
deemed to have been paid in the Philippines equivalent to fifteen percent
10 
(15%), which represents the difference between the regular income tax and
11 
the fifteen percent (15%) tax on dividends as provided in this subparagraph:
12 
Provided, That effective July 1, 2020, the credit against the tax due shall be
13 
equivalent to the difference between the regular income tax rate provided in
14 
Section 28(B)(1) of this code and the fifteen percent (15%) tax on dividends;
15 
[(c) Capital Gains from Sale of Shares of Stock not Traded in the Stock
16 
Exchange. - A final tax at the rate of fifteen percent (15%) is hereby imposed
17 
upon the net capital gains realized during the taxable year from the sale, barter,
18 
exchange or other disposition of shares of stock in a domestic corporation,
19 
except shares sold, or disposed of through the stock exchange.]"
20
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SEC. 9. Section 32 of the National Internal Revenue Code of 1997, as amended, is
22 
hereby amended to read as follows:
23
24 
SEC. 32. Gross Income. - x x x
25 
(B) Exclusions from Gross Income. - The following items shall not be included
26 
in gross income and shall be exempt from taxation under this Title:
27 
XXX XXX XXX
28 
(7) Miscellaneous Items. -
29 
XXX XXX XXX
30 
[(g) Gains from the Sale of Bonds, Debentures or other Certificate of
31 
Indebtedness. - Gains realized from the same or exchange or retirement of
24


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bonds, debentures or other certificate of indebtedness with a maturity of more
2 
than five (5) years.]
3 
(G) INTEREST INCOME, AND GAINS FROM THE SALE, TRANSFER, OR
4 
DISPOSITION OF PROJECT-SPECIFIC BONDS THAT ARE ISSUED BY
5 
THE REPUBLIC OF THE PHILIPPINES OR ANY OF ITS
6 
INSTRUMENTALITIES TO FINANCE CAPITAL EXPENDITURES OR
7 
PROGRAMS COVERED BY THE PHILIPPINE DEVELOPMENT PLAN OR
8 
ITS EQUIVALENT AND OTHER GOVERNMENT PROGRAMS
9 
CONSIDERED TO BE OF HIGH-LEVEL PRIORITY OF THE COUNTRY, AS
10 
DETERMINED BY THE SECRETARY OF FINANCE.
11
12 
(h) Gains from Redemption of Shares OR UNITS OF PARTICIPATION in [Mutuai
13 
Fund.] COLLECTIVE INVESTMENT SCHEMES - Gains realized by the
14 
investor upon redemption of shares of stock [in a mutual fund company] OR
15 
UNITS OF PARTICIPATION IN A COLLECTIVE INVESTMENT SCHEME
16 
as defined [in] UNDER Section 22 [BB] (LL) of this Code PROVIDED, THAT,
17 
PRIOR SUCH REDEMPTION, FINAL TAXES ON SUCH GAINS HAVE
18 
BEEN PREVIOUSLY WITHHELD AT THE LEVEL OF THE COLLECTIVE
19 
INVESTMENT SCHEME.
20 
XXX XXX XXX
21
22 
SEC. 10. Section 34 of the National Internal Revenue Code of 1997, as amended, is
23 
hereby further amended to read as follows;
24 
SEC. 34. Deductions from Gross Income. - Except for taxpayers earning
25 
compensation income arising from personal services rendered under an
26 
employer-employee relationship where no deductions shall be allowed under
27 
this Section, in computing taxable income subject to income tax under Sections
28 
24(A); 25(A); 26; 27(A), (B), and (C); and 28(A)(1), there shall be allowed the
29 
following deductions from gross income:
30 
(A) Expenses. - x x x
31 
(1) Ordinary and Necessary Trade, Business or Professional Expenses. -
32 
(a) In General. - x x x
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XXX XXX XXX
(B) Interest. -
(1) 
In General. - X X X
(2) Exceptions. - x x x
(a) If within the taxable year an individual taxpayer reporting income on the 
cash basis incurs an indebtedness on which an interest is paid in advance 
through discount or otherwise: Provided, That such interest shall be allowed as 
a deduction in the year the indebtedness is paid: Provided further, That if the 
indebtedness is payable in periodic amortizations, the amount of interest which 
corresponds to the amount of the principal amortized or paid during the year 
shall be allowed as deduction in such taxable year; OR
(b) If both the taxpayer and the person to whom the payment has been made 
or is to be made are persons specified under Section 36(B)[; or].
[(c) If the indebtedness is incurred to finance petroleum exploration.]
(3) Optional Treatment of Interest Expense RELATED TO ACQUISITION OF 
ASSET. - At the option of the taxpayer, interest EXPENSE incurred to acquire 
property used in trade, business or exercise of a profession THAT WILL 
BENEFIT THE BUSINESS FOR MORE THAN ONE YEAR may be allowed as 
a deduction FROM GROSS INCOME or [treated as a capital expenditure] BE 
CAPITALIZED AND THEREAFTER AMORTIZED OR DEPRECIATED AS 
PART OF THECOST OF THE ASSET.
XXX XXX XXX
(E) Bad Debts. -
(1) In General. - x x x
(2) Securities Becoming Worthless. - If securities, as defined in Section 22(T), 
are ascertained to be worthless and charged off within the taxable year and 
are capital assets, the loss resulting therefrom shall, [in the case of a taxpayer 
other than a bank or trust company incorporated under the laws of the 
Philippines a substantial part of whose business is the receipt of deposits, for 
the purpose of this Title,] be considered as a loss from the sale or exchange
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OF CAPITAL ASSETS, on the last day of such taxable year[, of capital assets].
SECURITIES HELD BY A DEALER IN SECURITIES OR AN ENTITY 
LICENSED BY THE APPROPRIATE GOVERNMENT REGULATORY 
AGENCIES TO BUY AND SELL IN SECURITIES INCLUDING BANKS AND 
OTHER FINANCIAL INTERMEDIARIES, SHALL BE CONSIDERED 
ORDINARY ASSETS, AND SECURITIES HELD THAT ARE ASCERTAINED 
TO BE WORTHLESS SHALL BE CONSIDERED ORDINARY LOSSES THAT 
ARE ALLOWED AS DEDUCTION FROM TAXABLE INCOME.
XXX XXX XXX
(L) Optional Standard Deduction (OSD). - In lieu of the deductions allowed 
under the preceding Subsections, an individual subject to tax under Section 24, 
other than a nonresident alien, [may elect a standard deduction in an amount 
not exceeding forty percent (40%) of his gross sales or gross receipts, as the 
case may be. In the case of a] AND A corporation CLASSIFIED AS A MICRO, 
SMALL AND MEDIUM-SIZED ENTERPRISE UNDER REPUBLIC ACT NO. 
6977, AS AMENDED, OTHERWISE KNOWN AS THE "MAGNA CARTA 
FOR SMALL ENTERPRISES", AND subject to tax under Sections 27(A) and 
28(A)(1), [it] may elect a standard deduction in an amount not exceeding forty 
percent (40%) of its gross income as defined in Section 32 of this Code. Unless 
the taxpayer signifies in [his] THE TAX return [his] THE intention to elect the 
optional standard deduction, [he] THE TAXPAYER shall be considered as 
having availed [himself] of the deductions allowed in the preceding 
Subsections. Such election when made in the return shall be irrevocable for the 
taxable year for which the return is made: Provided, that an individual who is 
entitled to and claimed for the optional standard deduction shall not be required 
to submit with [his] THE tax return such financial statements otherwise 
required under this Code: [Provided, further. That a general professional 
partnership and the partners comprising such partnership may avail of the 
optional standard deduction only once, either by the general professional 
partnership or the partners comprising the partnership:] Provided 
[finally,]FURTHER, That except when the Commissioner otherwise permits, 
the said individual shall keep such records pertaining to [his] gross sales or
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gross receipts, or the said corporation shall keep such records pertaining to 
[his] THE gross income as defined in Section 32 of this Code during the taxable 
year, as may be required by the rules and regulations promulgated by the 
Secretary of Finance, upon recommendation of the Commissioner.
XXX XXX 
XXX
SEC. 11. Section 37 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
"SEC. 37. Special Provisions Regarding Income and Deductions of Insurance 
Companies, Whether Domestic or Foreign. -
(A) 
Special Deduction Allowed to Insurance Companies, PRE-NEED 
COMPANIES, AND PENSION FUNDS. - In the case of insurance companies, 
PRE-NEED COMPANIES, AND PENSION FUNDS, whether domestic or 
foreign doing business in the Philippines, the net additions, if any, required by 
law to be made within the year to reserve funds and the sums other than 
dividends paid within the year on policy and annuity contracts may be deducted 
from their gross income. Provided, however. That the released reserve be 
treated as income for the year of release.
(B) Mutual Insurance Companies. - In the case of MUTUAL LIFE, mutual fire 
and mutual employers' liability and mutual workmen's compensation and 
mutual casualty insurance companies requiring their members to make 
premium deposits to provide for losses and expenses, said companies shall not 
INCLUDE [return] as income any portion of the premium deposits returned to 
their policyholders, but shall INCLUDE [return] as taxable income all income 
received by them from all other sources plus such portion of the premium 
deposits as are retained by the companies for purposes other than the payment 
of losses and expenses and reinsurance reserves.
XXX XXX XXX
SEC. 12. Section 38 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
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SEC. 38. Losses from Wash Sales of Stock or Securities. - (A) In the case of
2 
any loss claimed to have been sustained from any sale or other disposition of
3 
shares of stock or securities where it appears that within a period beginning
4 
thirty (30) days before the date of such sale or disposition and ending thirty
5 
(30) days after such date, the taxpayer has acquired (by purchase or by
6 
exchange upon which the entire amount of gain or loss was recognized by law),
7 
or has entered into a [contact] CONTRACT or option so AS to acquire,
8 
substantially identical stock or securities, then no deduction for the loss shall
9 
be allowed under Section 34 unless the claim is made by a dealer in stock or
10 
securities OR BY ANY ENTITY OR FINANCIAL INTERMEDIARY DULY
11 
LICENSED 
BY THE APPROPRIATE GOVERNMENT REGULATORY
12 
AGENCIES TO BUY AND SELL IN SECURITIES EITHER FOR THE
13 
ENTITY'S OWN ACCOUNT OR FOR THE ACCOUNT OF OTHERS and with
14 
respect to a transaction made in the ordinary course of the business of such
15 
dealer.
16 
XXX XXX XXX
17
18 
SEC. 13. Section 39 of the National Internal Revenue Code of 1997, as amended, is
19 
hereby amended to read as follows:
20 
SEC. 39. Capital Gains and Losses. -
21 
(A) Definitions. - As used in this Title -
22 
XXX XXX XXX
23 
[(B) Percentage Taken Into Account. - In the case of a taxpayer, other than a
24 
corporation, only the following percentages of the gain or loss recognized upon
25 
the sale or exchange of a capital asset shall be taken into account in computing
26 
net capital gain, net capital loss, and net income:]
27 
[(1) One hundred percent (100%) if the capital asset has been held for not
28 
more than twelve (12) months; and]
29 
[(2) Fifty percent (50%) if the capital asset has been held for more than twelve
30 
(12) months;]
31 
[(C)](B) Limitation on Capital Losses. - Losses from sales or exchanges of
32 
capital assets shall be allowed only to the extent of the gains from such sales
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or exchanges. If a [bank or trust company incorporated under the loss of the 
Philippines, a substantiai part of whose business is the receipt of deposits,] 
DEALER IN SECURITIES OR OTHER ENTITIES OR FINANCIAL 
INTERMEDIARIES DULY LICENSED BY THE APPROPRIATE 
GOVERNMENT REGULATORY AGENCIES TO TRADE IN SECURITIES, 
sells any bond, debenture, note, or certificate or other evidence of 
indebtedness issued by any corporation [(], inciuding one issued by a 
government or political subdivision thereof[)], with interest coupons or in 
registered form, any ioss resuiting from such sale shall not be subject to the 
foregoing limitation and shall not be included in determining the applicability of 
such limitation to other losses.
[(D) Net Capital Loss Carry-over. - If any taxpayer, other than a corporation, 
sustains in any taxable year a net capital loss, such loss (in an amount not in 
excess of the net income for such year) shall be treated in the succeeding 
taxabie year as a loss from the sale or exchange of a capital asset held for not 
more than twelve (12) months.]
[(E)](C) Retirement of Bonds, etc. - x x x
[(F) Gains or Losses from Short Sales, Etc. - For purposes of this Title -]
[(1) Gains or losses from short sales of property shall be considered as gains 
or iosses from sales or exchanges of capital assets; and]
[(2) Gains or losses attributable to the failure to exercise priviieges or options 
to buy or sell property shall be considered as capitai gains or iosses.]
SEC. 14. Section 42 of the Nationai Internal Revenue Code of 1997, as amended, is 
hereby amended to read as foiiows:
SEC. 42. Income from Sources Within the Philippines. - 
(A) Gross Income from Sources Within the Philippines. - The following items 
of gross income shaii be treated as gross income from sources within the 
Philippines:
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(1) Interests. - Interests AND YIELD [derived from sources within the
2 
Philippines, and interests on] 
FROM DEBT INSTRUMENTS, 
BANK
3 
DEPOSITS, DEPOSIT SUBSTITUTES, TRUST FUNDS, AND SIMILAR
4 
ARRANGEMENTS SUCH AS bonds, notes or other interest-bearing
5 
obligations of residents, corporate or otherwisef;], INCLUDING DEBT
6 
INSTRUMENTS OR DEBT SECURITIES ISSUED BY THE GOVERNMENT
7 
OR ANY OF ITS AGENCIES OR INSTRUMENTALITIES;
8 
(2) Dividends. - The amount received as dividends:
9 
(a) From a domestic corporation; and
10 
(b) From a foreign corporation, [unless less than] WITH AT LEAST fifty
11 
percent (50%) of the gross income of such foreign corporation for the three-
12 
year period ending with the close of its taxable year preceding the declaration
13 
of such dividends (or for such part of such period as the corporation has been
14 
in existence) was derived from sources within the Philippines as determined
15 
under the provisions of this Section; but only in an amount which bears the
16 
same ratio to such dividends as the gross income of the corporation for such
17 
period derived from sources within the Philippines bears [to] ON its gross
18 
income from all sources.
19 
XXX XXX XXX
20
21 
SEC. 15. Section 51 of the National Internal Revenue Code of 1997, as amended, is
22 
hereby amended to read as follows:
23 
"SEC. 51. Individual Return. -
24 
(A) Requirements. - x x x
25 
(B) Where to file. - x x x
26 
(C) When to File. - x x x
27 
(1) X X X
28 
(2) Individuals subject to tax on capital gains:
29 
(a) From the sale or exchange of shares of stock not traded [thru] THROUGH
30 
a [local] stock exchange OR AN ORGANIZED MARKETPLACE as
31 
prescribed under [Section] SECTIONS 24[(C)](B) (3), AND 25(A) AND
32 
(B), [shall file] a return SHALL BE FILED within thirty (30) days after
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each transaction and a final consolidated return on or before April 15 of each 
year covering aii stock transactions of the preceding taxabie year; and 
(b) From the sale or disposition of real property under Section 24[(D)] (B) (4) 
shall file a return within thirty (30) days following each sale or other disposition.
XXX XXX XXX
SEC. 16. Section 52 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as foiiows:
SEC. 52. Corporation Returns. - 
(A) Requirements. - x x x
XXX XXX
XXX
(D) Return on Capitai Gains Realized from Saie of Shares of Stock not Traded 
in the [Local] Stock Exchange OR AN ORGANIZED MARKETPLACE. - Every 
corporation deriving capital gains from the saie or exchange of shares of stock, 
not traded [thru] THROUGH a local stock exchange OR AN ORGANIZED 
MARKETPLACE as prescribed under SECTIONS 27(D)(3), 28(A)(1) AND 
(B)(5)(A) [Sections 24(C), 25(A)(3), 27(E)(2), 28(A)(8)(c) and 28(B)(5)(c),] 
shali fiie a return within thirty (30) days after each transaction and a final 
consolidated return of all transactions during the taxable year on or before the 
fifteenth (15th) day of the fourth (4th) month following the ciose of the taxabie 
year.
SEC. 17. Section 54 of the National Internal Revenue Code of 1997, as amended, is
hereby amended to read as follows:
"SEC. 54. Returns of Receivers, Trustees, [in Bankruptcy] or Assignees. - [In 
cases wherein receivers] RECEIVERS, ADMINISTRATORS, trustees in A 
TRUST OR bankruptcy, or ANY OTHER PERSON ASSIGNED OR [assignees 
are] IN CHARGE OF operating the property or business of [a]ANOTHER
32


1 
PERSON OR corporation, subject to the tax UNDER THIS CODE [imposed
2 
by this Title, such receivers, trustees or assignees] shall BE IMPOSED WITH
3 
THE OBLIGATION TO FILE [make] THE returns AND PAY THE TAXES FOR
4 
SUCH PERSON OR CORPORATION IN THE SAME MANNER REQUIRED
5 
UNDER THIS CODE, [of net income as and for such corporation, in the same
6 
manner and form as such organization is hereinbefore required to make
7 
returns, and any] ANY tax due on the income as returned by receivers,
8 
ADMINISTRATORS, trustees or assignees shall be assessed and collected in
9 
the same manner as if assessed directly against the [organizations] PERSON,
10 
ESTATE OR ORGANIZATION [of] whose businesses or properties they have
11 
custody OF or control OVER.
12
13 
SEC. 18. Section 56 of the National Internal Revenue Code of 1997, as amended, is
14 
amended to read as follows;
15
16 
"SEC. 56. Payment and Assessment of Income Tax for Individuals and
17 
Corporations. -
18 
(A) Payment of Tax. -
19 
XXX XXX XXX
20 
(3) Payment of Capital Gains Tax. - The total amount of tax imposed and
21 
prescribed under [Section] SECTIONS 24[(C)](B)(3), 24[(D)](B)(4), 25,
22 
27[(E)(2)](D)(3), 27(D)(4), 28(A)[(8)(c)] and 28(B)(5)[(c)] shall be paid on
23 
the date the return prescribed therefor is filed by the person liable thereto:
24 
Provided, That if the seller submits proof of [his] THE intention to avail
25 
[himself] of the benefit of exemption of capital gains under existing special laws
26 
OR TAX TREATY, no such payments shall be required: Provided[,] further,
27 
That in case of failure to qualify for exemption under such special laws, TAX
28 
TREATY and implementing rules and regulations, the tax due on the gains
29 
realized from the original transaction shall immediately become due and
30 
payable, and subject to the penalties prescribed under applicable provisions of
31 
this Code: Provided[,] finally. That if the seller, having paid the tax, submits
32 
such proof of intent within six (6) months from the registration of the document
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transferring the real property, [he] THE SELLER shall be entitled to a refund 
of such tax upon verification of [his] compliance with the requirements for such 
exemption.
XXX XXX XXX
SEC. 19. Section 57 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
"SEC. 57. Withholding of Tax at Source. -
(A) Withholding of Final Tax on Certain Incomes. - Subject to rules and 
regulations the Secretary of Finance may promulgate, upon the 
recommendation of the Commissioner, requiring the filing of income tax return 
by certain income payees, the tax imposed or prescribed [by] UNDER Sections 
[24(B)(1), 24(B)(2), 24(C), 24(D)(1); 25(A)(2), 25(A)(3), 25(B), 25(C), 25(D), 
25(E); 27(D)(1), 27(D)(2), 27(D)(3), 27(D)(5); 28(A)(4), 28(A)(5), 28(A)(7)(a), 
28(A)(7)(b), 28(A)(7)(c), 28(B)(1), 28(B)(2), 28(B)(3), 28(B)(4), 28(B)(5)(a), 
28(B)(5)(b), 28(B)(5)(c)] 24(B), 24(C), 25(B), 27(D), AND 28(B)(5); 33; 
and 282 of this Code on specified items of income SUBJECT TO FINAL TAX shall 
be withheld by payor-corporation and/or person and paid in the same manner 
and subject to the same conditions as provided in Section 58 of this Code.
XXX XXX XXX
SEC. 20. Section 73 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
"SEC. 73. Distribution of Dividends or Assets by Corporations. - 
(A) Definition of Dividends. - The term 'dividends' when used in this Title 
means any distribution made by a corporation to its shareholders out of its 
earnings or profits and payable to its shareholders, whether in money or in 
other property.
[Where a corporation distributes all of its assets in complete liquidation or 
dissolution, the gain realized or loss sustained by the stockholder, whether
34


1 
individual or corporate, is a taxable income or a deductible loss, as the case
2 
may be.]
3 
(B) Stock Dividend. - x x x
4 
(C) LIQUIDATING DIVIDENDS. - LIQUIDATING DIVIDENDS ARE
5 
DIVIDENDS REPRESENTING THE REMAINING GAINS REALIZED OR
6 
LOSS SUSTAINED BY THE STOCKHOLDER IN A COMPLETE
7 
LIQUIDATION OR DISSOLUTION BY A CORPORATION AND SHALL BE
8 
CONSIDERED AS TAXABLE INCOME OR A DEDUCTIBLE LOSS, UNDER
9 
SECTIONS 24(A), 25(A), 25(B), 27(A), 28(A) AND 28 (B), AS THE CASE
10 
MAY BE.
11 
[(C)](D) Dividends Distributed are Deemed Made from Most Recently
12 
Accumulated Profits. - x x x
13 
XXX XXX XXX
14 
SEC. 21. Section 108 of the National Internal Revenue Code of 1997, as amended, is
15 
hereby amended to read as follows:
16
17 
SEC. 108. Value-added Tax on Sale of Services and Use or Lease of Properties.
18
19 
(A) Rate and Base of Tax. — x x x
20 
The phrase "sale or exchange of services" means the performance of all kinds
21 
of services in the Philippines for others for a fee, remuneration or consideration,
22 
including those performed or rendered by construction and service contractors;
23 
stock, real estate, commercial, customs and immigration brokers; lessors of
24 
property, whether personal or real; warehousing services; lessors or
25 
distributors of cinematographic films; persons engaged in milling processing,
26 
manufacturing or repacking goods for others; proprietors, operators or keepers
27 
of hotels, motels, rest houses, pension houses, inns, resorts; proprietors or
28 
operators of restaurants, refreshment parlors, cafes and other eating places,
29 
including clubs and caterers; dealers in securities; [lending investors;]
30 
transportation contractors on their transport of goods or cargoes, including
31 
persons who transport goods or cargoes for hire and other domestic common
32 
carriers by land relative to their transport of goods or cargoes; common carriers
35


1 
by air and sea relative to their transport of passengers, goods or cargoes from
2 
one place in the Philippines to another place in the Philippines; sales of
3 
electricity by generation companies, transmission by any entity, and distribution
4 
companies, including electric cooperatives; services of franchise grantees of
5 
electric utilities, telephone and telegraph, radio and television broadcasting and
6 
all other franchise grantees except those under Section 119 of this Code, and
7 
non-life insurance companies (except their crop insurances), including surety,
8 
fidelity, indemnity, and bonding companies; and similar services regardless of
9 
whether or not the performance thereof calls for the exercise or use of the
10 
physical or mental faculties. The phrase "sale or exchange of services" shall
11 
likewise include:
12 
XXX XXX XXX
13
14 
SEC. 22. Section 109 of the National Internal Revenue Code of 1997, as amended, is
15 
hereby further amended to read as follows:
16
17 
"SEC. 109. Exempt Transactions. -
18 
(1) Subject to the provisions of Subsection (2) hereof, the following
19 
transactions shall be exempt from the value-added tax:
20 
(A) X X X
21 
XXX XXX XXX
22 
(DD) PREMIUMS COLLECTED BY NON-LIFE REINSURANCE
23 
COMPANIES ON TRANSACTIONS WHERE THE TAX ON THE DIRECT
24 
PREMIUM HAS ALREADY BEEN PAID BY THE DIRECT INSURER:
25 
PROVIDED, THAT THE SECRETARY OF FINANCE, UPON THE
26 
RECOMMENDATIONS OF THE COMMISSIONER OF INTERNAL
27 
REVENUE AND INSURANCE COMMISSIONER, SHALL PROMULGATE
28 
THE RULES ON THE REQUIRED REPORTS TO BE SUBMITTED TO THE
29 
BUREAU OF INTERNAL REVENUE. ANY NON-PAYMENT OF THE TAX OR
30 
MISREPRESENTATION SHALL SUBJECT THE DIRECT INSURER OR
31 
REINSURER TO PAY UNPAID TAXES AND PENALTIES UNDER THIS
32 
CODE.
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XXX XXX XXX
SEC. 23. Section 112 of the National Internal Revenue Code of 1997, as amended, is
hereby further amended to read as follows:
SEC. 112. Refunds [or Tax Credits] of Input Tax. -
(A) Zero-Rated or Effectively Zero-Rated Sales. - Any VAT-registered person, 
whose sales are zero-rated or effectively zero-rated may, within two (2) years 
after the close of the taxable quarter when the sales were made, apply for [the 
issuance of a tax credit certificate or] refund of creditable input tax due or paid 
attributable to such sales, except transitional input tax, to the extent that such 
input tax has not been applied against output tax: Provided, however. That in 
the case of zero-rated sales under Section 106(A)(2)(a)(l), (2) and [(b) and] 
Section 108 (B)(1) and (2), the acceptable foreign currency exchange proceeds 
thereof had been duly accounted for in accordance with the rules and 
regulations of the Bangko Sentral ng Pilipinas (BSP): Provided[,] further. That 
where the taxpayer is engaged in zero-rated or effectively zero-rated sale and 
also in taxable or exempt sale of goods or properties or services, and the 
amount of creditable input tax due or paid cannot be directly and entirely 
attributed to any one of the transactions, it shall be allocated proportionately 
on the basis of the volume of sales: Provided[,] finally. That for a person making 
sales that are zero-rated under Section 108(B)(6), the input taxes shall be 
allocated ratably between his zero-rated and non- zero-rated sales.
(B) Cancellation of VAT Registration. - A person whose registration has been 
cancelled due to retirement from or cessation of business, or due to changes 
in or cessation of status under Section 106(C) of this Code may, within two (2) 
years from the date of cancellation, apply for [the issuance of a tax credit 
certificate for any unused input tax which may be used in payment of his other 
internal revenue taxes] A REFUND OF SUCH UNUSED INPUT TAXES.
XXX XXX XXX
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SEC. 24. Section 121 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 121. Tax on Banks and Non-Bank Financial Intermediaries Performing 
Quasi-Banking Functions. - There shall be collected a tax on gross receipts 
derived from sources within the Philippines by all banks and non-bank financial 
intermediaries PERFORMING QUASI-BANKING FUNCTIONS AT THE 
RATE OF FIVE PERCENT (5%) ON INCOME SUCH AS INTEREST, 
COMMISSIONS, AND DISCOUNTS FROM LENDING ACTIVITIES AS 
WELL AS INCOME FROM FINANCIAL LEASING, ROYALTIES, RENTALS 
OF PROPERTY, REAL OR PERSONAL, PROFITS FROM SALE OR 
EXCHANGE INCLUDING GAINS DERIVED FROM SALE OR TRANSFER 
OF REAL PROPERTIES, NET TRADING GAINS WITHIN THE TAXABLE 
YEAR OF FOREIGN CURRENCY, DEBT SECURITIES, DERIVATIVES, 
AND OTHER SIMILAR FINANCIAL INSTRUMENTS, AND ALL OTHER 
ITEMS TREATED AS GROSS INCOME UNDER SECTION 32 OF THIS 
CODE, EXCEPT DIVIDENDS AND EQUITY SHARES AND NET INCOME 
OF SUBSIDIARIES WHICH SHALL BE SUBJECT TO ZERO PERCENT 
(0%) TAX [in accordance with the following schedule]:
[(a) On interest, commissions and discounts from lending activities as well as 
income from financial leasing, on the basis of remaining maturities of 
instruments from which such receipts are derived:]
[Maturity period is five years or less.............. 5%]
[Maturity period is more than five years........1%]
[(b) On dividends and equity shares and net income of subsidiaries ....0%]
[(c) On royalties, rentals of property, real or personal, profits, from exchange 
and all other items treated as gross income under Section 32 of this Code - 
..........................7%]
[(d) On net trading gains within the taxable year of foreign currency, debt
securities, derivatives, and other similar financial instruments-........ 7%]
Provided, however. That in case the maturity period referred to in paragraph 
(a) is shortened [thru] THROUGH pre-termination, then the maturity period
38


1 
shall be reckoned to end as of the date of pre-termination for purposes of
2 
classifying the transaction and the correct rate of tax shall be applied
3 
accordingly.
4 
Provided finally, That, the generally accepted accounting principles [as may be]
5 
prescribed by the Bangko Sentral ng Pilipinas for the bank or non-bank financial
6 
intermediary performing quasi-banking functions shall [likewise] be the basis
7 
for the calculation of gross receipts.
8 
XXX XXX XXX
9 
SEC. 25. Section 122 of the National Internal Revenue Code of 1997, as amended, is
10 
hereby amended to read as follows:
11
12 
SEC. 122. Tax on Other Non-Bank Financial Intermediaries. - There shall be
13 
collected a tax of five percent (5%) on the gross receipts derived by other non-
14 
bank financial intermediaries doing business in the Philippines, from interest,
15 
commissions, discounts AND DISCOUNTS FROM LENDING ACTIVITIES,
16 
AS WELL AS INCOME FROM FINANCIAL LEASING, ROYALTIES,
17 
RENTALS OF PROPERTY, REAL OR PERSONAL, PROFITS FROM SALE
18 
OR EXCHANGE INCLUDING GAINS DERIVED FROM SALE OR
19 
TRANSFER OF REAL PROPERTIES, NET TRADING GAINS WITHIN
20 
THE TAXABLE YEAR OF FOREIGN CURRENCY, DEBT SECURITIES,
21 
DERIVATIVES, AND OTHER SIMILAR FINANCIAL INSTRUMENTS,
22 
UNDERWRITING FEES, SERVICE INCOME, AND ALL OTHER ITEMS
23 
TREATED AS GROSS INCOME UNDER SECTION 32 OF THIS CODE,
24 
EXCEPT DIVIDENDS AND EQUITY SHARES AND NET INCOME OF
25 
SUBSIDIARIES WHICH SHALL BE SUBJECT TO ZERO PERCENT (0%).
26 
[and all other items treated as gross income under this Code: Provided, That
27 
interests, commissions and discounts from lending activities, as well as income
28 
from financial leasing, shall be taxed on the basis of the remaining maturities
29 
of the instruments from which such receipts are derived, in accordance with
30 
the following schedule:]
31 
[Maturity is (5) five years of less................... 5%]
32 
[Maturity period is more than (5) five years..... 1%]
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[Provided, however, That in case the maturity period is shortened 
pretermination, then the maturity period shall be reckoned to end as of the 
date of pretermination for purposes of classifying the transaction and the
correct rate of tax shall be applied accordingly.]
1
FINANCIAL INTERMEDIARIES SUBJECT TO TAX UNDER THIS 
SECTION SHALL INCLUDE FINANCING COMPANIES, FINANCE 
leasing companies, INVESTMENT HOUSES, PAWNSHOPS, 
FOREIGN EXCHANGE DEALERS AND MONEY BROKERS, TRUST 
ENTITIES, CREDIT CARD COMPANIES, LENDING INVESTORS, 
SAVINGS AND LOAN ASSOCIATIONS, AND OTHER FINANCIAL 
INTERMEDIARIES EXCEPT BANKS AND NON-BANKS PERFORMING 
QUASI-BANKING FUNCTIONS WHICH SHALL BE TAXED UNDER
SECTION 121 OF THIS CODE.
COLLECTIVE INVESTMENT SCHEMES SUCH AS MUTUAL FUNDS, UNIT 
LINKED INVESTMENT TRUST FUNDS, UNIT-LINKED VARIABLE
insurance, and other collective investment schemes shall 
not be subject to gross receipts tax and other
PERCENTAGE TAXES IMPOSED UNDER TITLE V AND THE VALUE 
added tax imposed under title IV OF THIS CODE. FOR 
PURPOSES OF THIS EXEMPnON, A CIS SHALL HAVE AT LEAST TWO 
HUNDRED (200) OWNERS, INVESTORS OR PARTICIPANTS, AND 
SHALL HAVE COMPLIED WITH THE MINIMUM PUBLIC OWNERSHIP 
requirement of THE APPROPRIATE GOVERNMENT REGULATORY
AGENCIES.
THE INCOME OF A PERSON OR COMPANY NOT LICENSED TO DO 
FINANCIAL INTERMEDIATION BUT WHICH ENGAGES IN FINANCIAL 
intermediation services AS AN INCIDENT TO ITS MAIN 
business activity, and derives income therefrom, shall be
SUBJECT TO THE TAX IMPOSED ON ITS PRINCIPAL ACTIVITY. TO BE
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CONSIDERED INCIDENTAL, THE INCOME FROM INTERMEDIATION 
SERVICES SHALL NOT EXCEED FIFTY PERCENT (50%) OF THE 
PERSON OR THE COMPANY'S TOTAL ANNUAL INCOME. IF THE TOTAL 
INCOME RECEIVED FROM FINANCIAL INTERMEDIATION IS MORE 
THAN FIFTY PERCENT (50%), AND THE PERSON OR COMPANY HAS 
ENTERED INTO AT LEAST SIX (6) TRANSACTIONS DURING THE YEAR, 
THE TOTAL INCOME FROM SUCH FINANCIAL INTERMEDIATION 
SHALL BE SUBJECT TO TAX UNDER THIS SUBSECTION.
Provided, finally, That the generally accepted accounting principles as may be 
prescribed by the Securities and Exchange Commission for other non-bank 
financial intermediaries shall likewise be the basis for the calculation of gross 
receipts.
Nothing in this Code shall preclude the Commissioner from imposing the same 
tax herein provided on persons OR ENTITIES performing similar [financing]
FINANCIAL INTERMEDIATION activities.
SEC. 26. Section 123 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 123. Tax on Life Insurance Premiums. - There shall be collected from 
every person, company or corporation, [Qexcept purely cooperative companies 
or associations[)] doing life insurance business of any sort in the Philippines, A
PREMIUM TAX AT THE FOLLOWING RATES:
(A) FOR LIFE INSURANCE, a tax of two percent (2%) of the total premium 
collected, whether such premiums are paid in money, notes, credits or any 
substitute for money; but premiums refunded within six (6) months after 
payment on account of rejection of risk or returned for other reason to a person 
insured shall not be included in the taxable receipts; nor shall any tax be paid 
upon reinsurance by a company IF THE TAX [that] has already BEEN paid 
[the tax] ON THE DIRECT PREMIUM; nor upon premiums collected or
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received by any branch of a domestic corporation, firm or association doing 
business outside the Philippines on account of any life insurance of the insured 
who is a nonresident, if any tax on such premium is imposed by the foreign 
country where the branch is established nor upon premiums collected or 
received on account of any reinsurance, if the insured, in case of personal 
insurance, resides outside the Philippines, if any tax on such premiums is 
imposed by the foreign country where the original insurance has been issued 
or perfected; nor upon that portion of the premiums collected or received by 
the insurance companies on variable contracts [(as defined in Section 232(2) 
of Presidential Decree No. 612),]AS DEFINED UNDER REPUBLIC ACT NO. 
10607, OTHERWISE KNOWN AS THE "INSURANCE CODE OF THE 
PHILIPPINES", IN A CIS in excess of the amounts necessary to insure the 
lives of the variable contract owners[.]: PROVIDED, THAT THE CIS SHALL 
HAVE AT LEAST TWO HUNDRED (200) OWNERS, INVESTORS OR 
PARTICIPANTS, AND THAT ANY MINIMUM PUBLIC OWNERSHIP AS 
MAY BE REQUIRED BY APPROPRIATE GOVERNMENT REGULATORY 
AGENCIES SHALL BE COMPLIED WITH.
(B) PERSONS DOING BUSINESS SIMILAR OR AKIN TO LIFE AND 
HEALTH INSURANCE SUCH AS PRE-NEED COMPANIES, PENSION 
FUND COMPANIES, HEALTH MAINTENANCE ORGANIZATIONS AND 
OTHER COMPANIES SIMILAR TO LIFE INSURANCE SHALL BE 
SUBJECT TO TAX UNDER THIS SUBSECTION AT THE RATE OF TWO 
PERCENT (2%) OF THE GROSS PREMIUM, PLAN PAYMENT, OR 
INSTALLMENT PAYMENTS COLLECTED WITHOUT ANY DEDUCTION 
FOR THE AMOUNTS REQUIRED BY THE APPROPRIATE 
GOVERNMENT REGULATORY AGENCIES TO BE EARMARKED FOR THE 
BENEFIT OF THE INSURED, OR PLANHOLDER.
NOTHING IN THIS CODE SHALL PRECLUDE THE COMMISSIONER 
FROM IMPOSING THE SAME TAX HEREIN PROVIDED ON PERSONS 
PERFORMING SIMILAR INSURANCE BUSINESS ACTIVITIES.
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LIFE REINSURANCE COMPANIES SHALL BE SUBJECT TO PREMIUM 
TAX ON PREMIUMS COLLECTED UNDER SUBSECTION (A) HEREOF. 
HOWEVER, PREMIUMS COLLECTED ON TRANSACTIONS WHERE THE 
TAX ON THE DIRECT PREMIUM HAS ALREADY BEEN PAID BY THE 
DIRECT INSURER SHALL BE EXCLUDED FROM THE GROSS PREMIUM 
SUBJECT TO PREMIUM TAX.
A VARIABLE INSURANCE CONTRACT WHERE AMOUNTS IN EXCESS OF 
INSURANCE COSTS ARE COLLECTED AS PART OF THE PREMIUM AND 
WHERE UNITS OF PARTICIPATION IN A POOLED FUND ARE ISSUED 
TO THE INSURED REPRESENTING THEIR RESPECTIVE SHARES IN 
THE POOLED FUND, IS A CIS. THE AMOUNTS OF PREMIUM 
COLLECTED IN EXCESS OF THE INSURANCE COST IS NOT SUBJECT TO 
PREMIUM TAX UNDER THIS SECTION AND TO THE GROSS RECEIPTS 
TAX IMPOSED UNDER SECTIONS 121 AND 122, OR TO ANY 
PERCENTAGE TAX IMPOSED UNDER TITLE V AND TO VALUE ADDED 
TAX UNDER SECTION 105, TITLE IV OF THIS CODE.
XXX XXX XXX
SEC. 27. Section 127 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
"SEC. 127. Tax on Sale, Barter or Exchange of Shares of Stock Listed and 
Traded through the Local Stock Exchange [or through Initial Public Offering].
(A) Tax on Sale, Barter or Exchange of Shares of Stock Listed and Traded 
through the Local Stock Exchange. - There shall be levied, assessed and 
collected on every sale, barter, exchange, or other disposition of shares of stock 
OF A DOMESTIC CORPORATION listed and traded through the local stock 
exchange, OR LISTED AND TRADED IN BOTH A LOCAL AND FOREIGN 
STOCK EXCHANGE, other than the sale by a dealer in securities, IN LIEU 
OF CAPITAL GAINS TAX, a tax at the rate of six-tenths of one percent (6/10
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of 1%) of the gross selling price or gross value in money of the shares of stock 
sold, bartered, exchanged or otherwise disposed which shali be paid by the 
seller or transferor: PROVIDED, THAT THE TAX RATE SHALL BE IMPOSED 
ACCORDING TO THE FOLLOWING SCHEDULE:
EFFECnVITY
FINAL TAX RATE
JANUARY 1, 2023
FIVE-TENTH OF ONE PERCENT (5/10
OF 1%)
JANUARY 1, 2024
FOUR-TENTH OF ONE PERCENT
(4/10 OF 1%)
JANUARY 1, 2025
THREE-TENTH OF ONE PERCENT
(3/10 OF 1%)
JANUARY 1, 2026
TWO-TENTH OF ONE PERCENT
(2/10 OF 1%)
JANUARY 1, 2027
ONE-TENTH OF ONE PERCENT (1/10
OF 1%)
ANY GAIN REALIZED FROM THE SALE, EXCHANGE, BARTER, OR 
DISPOSITION OF LISTED SHARES OF STOCK BY A DEALER IN 
SECURITIES LICENSED BY THE APPROPRIATE GOVERNMENT 
REGULATORY AGENCIES TO BUY AND SELL IN SECURITIES, FOR HIS 
OWN ACCOUNT IN THE ORDINARY COURSE OF BUSINESS, SHALL 
NOT BE SUBJECT TO TAX UNDER THIS SUBSECTION BUT TO SECTION 
27(A) AS AN ORDINARY INCOME.
[(B) Tax on Shares of Stock Sold or Exchanged Through Initial Public Offering.] 
- REPEALED in R.A. 11494
[(C) Return on Capitai Gains Reaiized from Sale of Shares of Stocks.-] 
[(1)](B) Return on [Capital Gains Realized from] Sale of Shares of Stock AND 
OTHER SECURITIES Listed and Traded in the Local Stock Exchange. - It shall 
be the duty of every stock broker who effected the sale subject to the tax 
imposed herein to collect the tax and remit the same to the Bureau of Internai 
Revenue within five (5) banking days from the date of collection thereof and to
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submit on Mondays of each week to the secretary of the stock exchange, of
2 
which he is a member, a true and complete return which shall contain a
3 
declaration of all the transactions effected through him during the preceding
4 
week and of taxes collected by him and turned over to the Bureau of Internal
5 
Revenue: PROVIDED, THAT FOR SALES OF SHARES OF STOCK OF A
6 
DOMESTIC CORPORATION LISTED AND TRADED IN BOTH A LOCAL
7 
AND FOREIGN STOCK EXCHANGE, THE COLLECTION AND
8 
REMITTANCE OF THE ABOVE TAX SHALL BE IN ACCORDANCE WITH
9 
THE RULES PROMULGATED BY THE SECRETARY OF FINANCE, UPON
10 
THE RECOMMENDATION OF THE COMMISSIONER OF INTERNAL
11 
REVENUE: PROVIDED FURTHER, THAT THE REMITTANCE OF THE
12 
SAID TAX SHALL BE WITHIN A PERIOD NOT EXCEEDING TEN (10)
13 
DAYS.
14 
[(2) Return on Public Offerings of Shares of Stock. - In case of primary offering,
15 
the corporate issuer shall file the return and pay the corresponding tax within
16 
thirty (30) days from the date of listing of the shares of stock in the local stock
17 
exchange. In the case of secondary offering, the provision of Subsection (C)(1)
18 
of this Section shall apply as to the time and manner of the payment of the
19 
tax.]
20 
(D) [Common Provisions. - anyJANY gain derived from the sale, barter,
21 
exchange or other disposition of shares of stock under this Section shall be
22 
exempt from the tax imposed in Sections [24(C), 27(D)(2), 28(A)(8)(c), and
23 
28(B)(5)(c)]24(B)(3), 27(D)(3), 28(A)(1) and 28(B)(5)(A) of this Code
24 
and from the regular individual or corporate income tax. Tax paid under this
25 
Section shall not be deductible for income tax purposes.
26
27 
SEC. 28. Section 130 of the National Internal Revenue Code of 1997, as amended,
28 
is hereby amended to read as follows:
29 
"SEC. 130. FILING OF RETURN AND PAYMENT OF EXCISE TAX ON
30 
DOMESTIC PRODUCTS -
31 
(A) PERSONS LIABLE TO FILE A RETURN, FILING OF RETURN ON
32 
REMOVAL AND PAYMENT OF TAX:
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(1) PERSONS LIABLE TO FILE A RETURN. XXX 
2) TIME FOR FILING OF RETURN AND PAYMENT OF THE TAX^X X X
S Ice for fiung of the return and payment of the tax.
XXX
(4) EXCEPTIONS:
(a) X X X
(b) X X X
(B) determination of gross selling price of goods sub:ect 
TO AD VALOREm^A. - UNLESS OTHERWISE PROVIDED, THE PRICE 
excluding THE VALUE-ADDED TAX, AT WHICH THE GOODS ARE 
S0LrAT WHOLESALE IN THE PLACE OF PRODUCTION OR
Tortation orthrough their sales agents to the pubuc
SHALL constitute THE GROSS SELLING PRICE. 
MANUFACTURER OR IMPORTER ALSO SELLS OR
goods to be sold at wholesale in another establishm
OF WHICH HE IS THE OWNER OR IN THE PROFITS OF WHICH HE HAS 
AN INTEREST, THE WHOLESALE
PRICE IS SUCH ESTABLISHMENT SHALL CONSTITU
sTlung price, should such price be less than the cost of 
manufacturer or importation plus expenses incurred 
1Tl t"e GOODS ARE FINALLY SOLD, THEN A PROPORTIONATE 
margin of PROHT not less than ten percent (10%, OF SUCH 
Iufacturing or importation cost and expenses, shall be 
added to constitute the gross selung price.
SEC. 29. section 149 of National Internal Revenue Code of 1997, as amended. Is 
hereby amended to read as follows.
SEC 149. Automobiles. - There shall be levied, assessed and collected a.r ad 
valorem tax on automobiles based on the manufacturer's or Importer s selling
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price, net of excise and value-added tax, in accordance with the following
2 
schedule:
3 
XXX XXX XXX
4
5 
Provided, That hybrid vehicles shall be subject to fifty percent (50%) of the
6 
applicable excise tax rates on automobiles under this Section: Provided[,]
7 
further. That purely electric vehicles [and pick-ups] shall be exempt from excise
8 
tax on automobiles.
9 
As used in this Section-
10 
(a) X X X
11 
(b) Trucks/cargo van shall mean a motor vehicle of any configuration that is
12 
exclusively designed for the carriage of goods and with any number of wheeis
13 
and axles[: Provided, that pick-ups shall not be considered as trucks].
14 
XXX XXX XXX
15 
SEC. 30. Section 174 of the National Internal Revenue Code of 1997, as amended, is
16 
hereby amended to read as follows:
17
18 
SEC. 174. Stamp Tax on Original Issue of Shares of Stock. - On every original
19 
issue, whether on organization, reorganization or for any lawful purpose, of
20 
shares of stock by any association, company, or corporation, INCLUDING
21 
SHARES OF STOCK OR UNITS OF PARTICIPATION IN A COLLECTIVE
22 
INVESTMENT SCHEME, there shall be collected a documentary stamp tax of
23 
[Two pesos (P2.00) on each Two hundred pesos (P200), or fractional part
24 
thereof, of the par value,] SEVENTY-FIVE PERCENT OF ONE PERCENT
25 
(75% OF 1%) OF THE PAR VALUE of such shares of stock: Provided, That
26 
in the case of the original issue of shares of stock without par value, the amount
27 
of the documentary stamp tax herein prescribed shall be based upon the actual
28 
consideration for the issuance of such shares of stock: Provided[,] further. That
29 
in the case of stock dividends, on the actual value represented by each share[.]:
30 
PROVIDED FINALLY, THAT IN THE CASE OF COLLECTIVE
31 
INVESTMENT SCHEMES WITHOUT PAR VALUE, THE DOCUMENTARY
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STAMP TAX SHALL BE BASED ON THE INITIAL NET ASSET VALUE PER 
UNIT."
SEC. 31. Section 175 of the National Internal Revenue Code of 1997, as amended, is 
hereby repealed.
SEC. 32. Section 176 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 176. StampTax on Bonds, Debentures, AND [Certificate] 
CERTIFICATES of Stock or Indebtedness Issued in Foreign Countries. - [On 
all] A DOCUMENTARY STAMP TAX OF SEVENTY-FIVE PERCENT OF 
ONE PERCENT (75% OF 1%) OF THE VALUE OF THE TRANSACTION 
SHALL BE COLLECTED FROM A PERSON SELLING OR TRANSFERING 
bonds, debentures, certificates of stock, or certificates of indebtedness issued 
in any foreign country[, there shall be collected from the person selling or 
transferring the same in the Philippines, such tax as is required by law on similar 
instruments when issued, sold or transferred in the Philippines]."
SEC. 33. Section 177 of the National Internal Revenue Code of 1997, as amended, is 
hereby repealed.
SEC. 34. Section 178 of the National Internal Revenue Code of 1997, as amended, is 
hereby repealed.
SEC. 35. Section 179 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 179. Stamp Tax on All Debt Instruments. - On every original issue of debt 
instruments, there shall be collected a documentary stamp tax of [One peso 
and fifty centavos (PI.50) on each Two hundred pesos (P200), or fractional 
part thereof,] SEVENTY-FIVE PERCENT OF ONE PERCENT (75% OF
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1%) of the issue price of any such debt instruments: Provided, That for such
2 
debt instruments with terms of less than one (1) year, the documentary
3 
stamp tax to be collected shall be of a proportional amount in accordance
4 
with the ratio of its term in number of days to three hundred sixty-five (365)
5 
days: Provided[,j further. That only one documentary stamp tax shall be
6 
imposed on either loan agreement, or promissory notes issued to secure such
7 
loan.
8 
For purposes of this section, the term 'debt instrument7 shall mean [debt]
9 
instruments representing borrowing and lending transactions including but not
10 
limited to debentures, certificates of indebtedness, due bills, bonds, loan
11 
agreements, including those signed abroad wherein the object of contract is
12 
located or used in the Philippines, instruments and securities issued by the
13 
government or any of its instrumentalities, deposit substitute debt instruments,
14 
certificates or other evidences of deposits that are either drawing interest
15 
significantly higher the regular savings deposit taking into consideration the
16 
size of the deposit and the risks involved or drawing interest and having a
17 
specific maturity date, [orders for payment of any sum of money otherwise
18 
than at sight or on demand,] promissory notes, whether negotiable or non-
19 
negotiable, except bank notes issued for circulation.
20 
SEC. 36. Section 180 of the National Internal Revenue Code of 1997, as amended, is
21 
hereby repealed.
22
23 
SEC. 37. Section 181 of the National Internal Revenue Code of 1997, as amended, is
24 
hereby amended to read as follows:
25 
SEC. 181. Stamp Tax Upon Acceptance of Bills of Exchange and Others.- Upon
26 
any acceptance or payment of any bill of exchange or order for the payment of
27 
money purporting to be drawn in a foreign country but payable in the
28 
Philippines, there shall be collected a documentary stamp tax OF THIRTY
29 
PERCENT OF ONE PERCENT (30% OF 1%) [Sixty centavos (P0.60) on
30 
each Two hundred pesos (P200), or fractional part thereof,] of the face value
31 
of any such bill of exchange, or order, or the Philippine equivalent of such value,
32 
if expressed in foreign currency.
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SEC. 38. Section 182 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 182. Stamp Tax on Foreign Bills of Exchange and Letters of Credit. - On 
all foreign bills of exchange and [letter] LETTERS of credit (including orders, 
by telegraph or otherwise, for the payment of money issued by express or 
steamship companies or by any person or persons) drawn in but payable out 
of the Philippines in a set of three (3) or more according to the custom of 
merchants and bankers, there shall be collected a documentary stamp tax OF 
THIRTY PERCENT OF ONE PERCENT (30% OF 1%) [Sixty centavos (P0.60) 
on each Two hundred pesos (P200), or fractional part thereof,] of the face 
value of any such bill of exchange or letter of credit, or the Philippine equivalent 
of such face value, if expressed in foreign currency[.]: PROVIDED, THAT A 
LETTER OF CREDIT ON WHICH THE DOCUMENTARY STAMP TAX 
IMPOSED UNDER THIS SECTION IS PAID UPON OPENING SHALL NOT 
BE SUBJECT AGAIN TO THE TAX IMPOSED BY SECTION 195 UPON 
AVAILMENT OF THE TRUST RECEIPT LINE WHERE THE PROPERTY 
SUBJECT OF THE LETTER OF CREDIT IS MADE A SECURITY FOR 
PAYMENT.
SEC. 39. Section 183 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 183. Stamp Tax on Life AND HEALTH Insurance Policies[.], ON 
ANNUITIES, AND HEALTH MAINTENANCE ORGANIZATION 
PRODUCTS. - On all policies of insurance or other instruments by whatever 
name the same may be called, whereby any insurance, POLICY ON 
ANNUITY, OR HEALTH MAINTENANCE ORGANIZATION PRODUCT shall 
be made or renewed upon any life or lives AND HEALTH OF PERSONS, there 
shall be collected a one-time documentary stamp tax at the following rates:
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If the amount of insurance does not exceed P100,000 - Exempt
If the amount of insurance exceeds P100,000 
but does not exceed P300,000
If the amount of insurance exceeds P300,000 
but does not exceed P500,000
If the amount of insurance exceeds P500,000 
but does not exceed P750,000
If the amount of insurance exceeds P750,000 
but does not exceed PI,000,000
If the amount of insurance exceeds P1,000,000
P20.00
P50.00
- PIOO.OO
- PI50.00
P200.00
SEC. 40. Section 184 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 184. Stamp Tax on Policies of Insurance Upon Property. - On all policies 
of insurance or other instruments by whatever name the same may be called, 
[by which insurance shall be] made or renewed upon property of any 
description, including rents or profits, against peril by sea or on inland waters, 
or by fire or lightning, there shall be collected a documentary stamp tax of 
[Fifty centavos (P0.50) on each Four pesos (P4.00), or fractional part thereof,] 
TWELVE AND ONE-HALF PERCENT (12.5%) of the amount of premium 
charged: Provided, however. That no documentary stamp tax shall be collected 
on reinsurance contracts or on any instrument by which cession or acceptance 
of insurance risks under any reinsurance agreement is effected or recorded: 
PROVIDED FURTHER, THAT SUCH TAX RATE SHALL BE IMPOSED 
ACCORDING TO THE FOLLOWING SCHEDULE:
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EFFECTIVITY
JANUARY 1, 2023 
JANUARY 1, 2024 
JANUARY 1, 2025 
JANUARY 1, 2026 
JANUARY 1, 2027
DOCUMENTARY STAMP TAX RATE ON 
PROPERTY INSURANCE POLICIES 
ELEVEN AND ONE-HALF PERCENT (11.5%) 
TEN AND ONE-HALF PERCENT (10.5%) 
NINE AND ONE-HALF PERCENT (9.5%) 
EIGHT AND ONE-HALF PERCENT (8.5%) 
SEVEN AND ONE-HALF PERCENT (7.5%)
SEC. 41. Section 185 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 185. Stamp Tax on Fidelity Bonds and Other Insurance Policies. - On all 
policies of insurance or bonds or obligations of the nature of indemnity for loss, 
damage or liability made or renewed by any person, association, company or 
corporation transacting the business of accident, fidelity, employer's liability, 
plate, glass, steam boiler, burglar, elevator, automatic sprinkler, or other 
branch of insurance (except life, marine, inland, and fire insurance), and all 
bonds, undertakings, or recognizances, conditioned for the performance of the 
duties of any office or position, for the doing or not doing of anything 
therein specified, and on all obligations guaranteeing the validity or legality 
of any bond or other obligations issued by any province, city, municipality, or 
other public body or organization, and on all obligations guaranteeing the title 
to any real estate, or guaranteeing any mercantile credits, which may be made 
or renewed by any such person, company or corporation, there shall be 
collected a documentary stamp tax of [Fifty centavos (P0.50) on each Four 
pesos (P4.00), or fractional part thereof,] TWELVE AND ONE-HALF 
PERCENT (12.5%) of the premium charged[.]: PROVIDED, THAT 
SUCH TAX RATE SHALL BE IMPOSED ACCORDING TO THE 
FOLLOWING SCHEDULE:
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EFFEC71VITY
JANUARY 1, 2023 
JANUARY 1, 2024 
JANUARY 1, 2025 
JANUARY 1, 2026 
JANUARY 1, 2027
DOCUMENTARY STAMP TAX RATE ON 
FIDELITY BONDS AND OTHER INSURANCE 
POLICIES
ELEVEN AND ONE-HALF PERCENT (11.5%)
TEN AND ONE-HALF PERCENT (10.5%)
NINE AND ONE-HALF PERCENT (9.5%)
EIGHT AND ONE-HALF PERCENT (8.5%)
SEVEN AND ONE-HALF PERCENT (7.5%)
SEC. 42. Section 186 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 186. Stamp Tax on [Policies of Annuities, and] Pre-Need Plans. - [On all 
policies of annuities, or other instruments by whatever name the same may be 
called, whereby an annuity may be made, transferred or redeemed, there shall 
be collected a documentary stamp tax of One peso (PI.00) on each Two 
hundred pesos (P200), or fractional part thereof, of the premium or installment 
payment on contract price collected.] On pre-need plans, [the documentary 
stamp tax shall be Forty centavos (P0.40) on each Two hundred pesos (P200), 
or fractional part thereof, of the premium or contribution collected.] THERE 
SHALL BE COLLECTED A DOCUMENTARY STAMP TAX OF TWENTY 
PERCENT OF ONE PERCENT (20% OF 1%) OF THE PREMIUM OR 
INSTALLMENT PAYMENT ON CONTRACT PRICE, OR CONTRIBUTION 
CHARGED.
SEC. 43. Section 187 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 187. Stamp Tax on Indemnity Bonds. - On all bonds for indemnifying any 
person, firm or corporation who shall become bound or engaged as surety for 
the payment of any sum of money or for the due execution or performance of 
the duties of any office or position or to account for money received by virtue
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thereof, and on all other bonds of any description, except such as may be 
required in legal proceedings, or are otherwise provided for herein, there shall 
be collected a documentary stamp tax of [Thirty centavos (P0.30) on each 
Four pesos (P4.00), or fractional part thereof,] SEVEN AND ONE-HALF 
PERCENT (7.5%) of the premium charged.
SEC. 44. Section 188 of the National Internal Revenue Code of 1997, as amended is 
hereby repealed.
SEC. 45. Section 190 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 190. Stamp Tax on Jai-Alai, Horse Racing Tickets, Lotto or Other 
Authorized Numbers Games. - On each jai-alai, horse race ticket, [lotto], or 
other authorized number games, there shall be collected a documentary stamp 
tax of Twenty [centavos (P0.20): Provided, That if the cost of the ticket 
exceeds One peso (Pl.OO), an additional tax of Twenty centavos (P0.20) on 
every One peso (Pl.OO), or fractional part thereof, shall be collected] 
PERCENT (20%) OF THE COST OF THE TICKET: PROVIDED, THAT ON 
EACH peso LOTTERY TICKET, THERE SHALL BE COLLECTED A 
DOCUMENTARY STAMP TAX OF TEN PERCENT (10%) OF THE COST OF 
THE TICKET.
SEC. 46. Section 192 of the National Internal Revenue Code of 1997, as amended is 
hereby repealed.
SEC. 47. Section 193 of the National Internal Revenue Code of 1997, as amended is 
hereby repealed.
SEC. 48. Section 195 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 195. Stamp Tax on Mortgages, Pledges and Deeds of Trust. - On every 
mortgage or pledge of lands, estate, or property, real or personal, heritable or
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movable, whatsoever, where the same shall be made as a security for the 
payment of any definite and certain sum of money lent at the time or previously 
due and owing or forborne to be paid, being payable, and on any conveyance 
of land, estate, or property whatsoever, in trust or to be sold, or otherwise 
converted into money which shall be and intended only as security, either by 
express stipulation or otherwise, there shall be collected a documentary stamp 
tax [at the following rates:] OF THIRTY PERCENT OF ONE PERCENT 
(0.30%) OF THE AMOUNT SECURED.
[(a) When the amount secured does not exceed Five thousand pesos (P5,000), 
Forty pesos (P40.00).]
[(b) On each Five thousand pesos (P5,000), or fractional part thereof in excess 
of Five thousand pesos (P5,000), an additional tax of Twenty pesos (P20.00).]
XXX XXX xxx"
SEC. 49. Section 198 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 198. Stamp Tax on [Assignments and] Renewals of Certain Instruments. 
- Upon each and every [assignment or transfer of any mortgage, lease or policy 
of insurance, or the] renewal or continuance of any agreement, contract, 
charter, or any evidence of obligation or indebtedness SUB3ECT TO 
DOCUMENTARY STAMP TAX UNDER THIS TITLE by THE EXTENSION 
OF THE TERM OR MATURITY [altering or otherwise,] OR ALTERATION OF 
SUCH AGREEMENT, CONTRACT OR CHARTER, there shall be levied, 
collected and paid a documentary stamp tax, at the same rate as that imposed 
on the original instrument.
SEC. 50. Section 199 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
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SEC. 199. Documents and Papers Not Subject to Stamp Tax. - The provisions 
of Section 173 to the contrary notwithstanding, the following instruments, 
documents and papers shall be exempt from the documentary stamp tax:
(a) X X X
XXX XXX XXX
(e) Sale, barter, [or] exchange, REDEMPTION OR OTHER DISPOSITION 
of shares of stock, OR UNITS OF PARTICIPATION IN A COLLECTIVE 
INVESTMENT SCHEME OR OTHER CIS SECURITIES, listed and traded 
through the local stock exchange. THE ORIGINAL ISSUANCE OF SHARES 
OR UNITS OF PARTICIPATION IN A CIS SHALL NOT BE COVERED BY 
THIS EXEMPTION.
XXX XXX XXX
(n) Interbank call loans with maturity of not more than [seven (7)] FIVE (5) 
days to cover deficiency in reserves against deposit liabilities, including those 
between or among banks and quasi-banks.
SEC. 51. Section 204 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 204. Authority of the Commissioner to Compromise, Abate and Refund or
Credit Taxes. - The Commissioner may -
(A) Compromise the payment of any internal revenue tax, when:
XXX XXX XXX
Where the basic tax involved exceeds [One million pesos (P1,000,000)] 
FIFTEEN MILLION PESOS (P15,000,000) or where the settlement offered 
is less than the prescribed minimum rates, the compromise shall be subject to 
the approval of the Evaluation Board which shall be composed of the 
Commissioner and the four (4) Deputy Commissioners."
XXX XXX XXX
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SEC. 52. Section 222 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
SEC. 222. Exceptions as to Period of Limitation of Assessment and Collection of 
Taxes. -
(a) X X X
(b) If before the expiration of the time prescribed in Section 203 for the 
assessment of the tax, [both the Commissioner and] the taxpayer [have 
agreed] APPLIES WITH THE COMMISSIONER in writing [to its] FOR 
assessment [after such time], the tax may be assessed within the period 
[agreed upon] SPECIFIED IN THE APPLICATION WHICH SHALL NOT 
EXCEED SIX (6) MONTHS AT ANY GIVEN TIME. [The] SUCH period [so 
agreed upon] may be extended by subsequent written [agreement] 
APPLICATION made before the expiration of the period previously [agreed 
upon] APPLIED FOR.
XXX XXX XXX
SEC. 53. Section 237 of the National Internal Revenue Code of 1997, as amended, is 
hereby further amended to read as follows:
SEC. 237. Issuance of Receipts or Sales or Commercial Invoices. - 
(A) Issuance. - x x x
Within five (5) years from the effectivity of this Act and upon the establishment 
of a system capable of storing and processing the required data, the Bureau 
shall require taxpayers engaged in the export of goods and services, taxpayers 
engaged in e-commerce, and taxpayers under the jurisdiction of the Large 
Taxpayers Service to issue AND TRANSMIT electronic receipts or sales or 
commercial invoices [in lieu of manual receipts or sales or commercial invoices] 
THROUGH DESIGNATED ELECTRONIC CHANNELS WITH A PUBLIC 
CERTIFICATION SYSTEM ACCREDITED BY THE BUREAU, subject to 
rules and regulations to be issued by the Secretary of Finance upon 
recommendation of the Commissioner [and after a] FOLLOWING A public
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hearing [shall have been] held for this purpose: Provided, That taxpayers not
2 
covered by the mandate of this provision may issue electronic receipts or, sales
3 
or commercial invoices, in lieu of manual receipts, and sales and commercial
4 
invoices[.]: PROVIDED FURTHER, THAT SUB3ECT TO THE RULES AND
5 
REGULATIONS TO BE ISSUED BY THE SECRETARY OF FINANCE, UPON
6 
THE RECOMMENDATION OF THE COMMISSIONER, THE BUREAU MAY
7 
REQUIRE ANY TAXPAYER TO COMPLY WITH THE PROVISIONS OF
8 
THIS SECTION.
9 
A PUBLIC CERTIFICATION SYSTEM SHALL REFER TO A DIGITAL
10 
PERSONAL AUTHENTICATION PROGRAM WITH ABILITY TO VERIFY
11 
THE IDENTITY OF THE ISSUING TAXPAYER AND ATTEST TO THE
12 
AUTHENTICITY OF THE INFORMATION IN THE ELECTRONIC
13 
RECEIPTS OR SALES OR COMMERCIAL INVOICES. THIS
14 
MAY INCLUDE THE USE OF DIGITAL SIGNATURE ISSUED BY
15 
CERTIFICATION AUTHORITY AS ACCREDITED BY THE BUREAU OF
16 
INTERNAL REVENUE.
17 
A DESIGNATED ELECTRONIC CHANNEL SHALL REFER TO ANY
18 
MEDIUM OR PORTAL IDENTIFIED BY THE BUREAU WITH AN ABILITY
19 
TO RECEIVE THE TRANSACTION DATA OF THE ELECTRONIC
20 
RECEIPTS OR SALES OR COMMERCIAL INVOICES FOR ASSIGNMENT
21 
OF AN APPROVED ELECTRONIC TAX TRANSACTION NUMBER.
22 
AN APPROVED TAX TRANSACTION NUMBER SHALL REFER TO THE
23 
UNIQUE ASSIGNED SERVICE NUMBERS AND/OR LETTERS LINKED TO
24 
A VALIDATED SALES TRANSACTION 
REPORTED THROUGH THE
25 
DESIGNATED ELECTRONIC CHANNEL.
26 
The original of each receipt or invoice shall be issued to the purchaser,
27 
customer or client at the time the transaction is effected, who, if engaged in
28 
business or in the exercise of profession, shall keep and preserve the same in
29 
his place of business for a period of three (3) years from the close of the taxable
30 
year in which such invoice or receipt was issued, while the duplicate shall be
31 
kept and preserved by the issuer, also in his place of business, for a like period:
32 
Provided, That in case of electronic receipts or sales or commercial invoices.
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the digital records of the same [shall be kept by the purchaser, customer or 
client and the issuer for the same period above stated] BEARING THE 
APPROVED ELECTRONIC TAX TRANSACTION NUMBER SHALL BE 
SUFFICIENT COMPLIANCE.
The Commissioner may, in meritorious cases, exempt any person subject to 
internal revenue tax from compliance with the provisions of this Section.
SEC. 54. Section 237-A of the National Internal Revenue Code of 1997, as amended,
is hereby amended to read as follows:
SEC. 237-A. Electronic Sales Reporting System. - Within five (5) years from the 
effectivity of this Act and upon the establishment of a system capable of storing 
and processing the required data, the Bureau shall require taxpayers engaged 
in the export of goods and services, AND TAXPAYERS ENGAGED IN E- 
COMMERCE and taxpayers under the jurisdiction of the Large Taxpayers 
Service to [electronically report their sales data to the Bureau through the use 
of electronic point of sales systems,] USE A SYSTEM CAPABLE OF ISSUING 
ELECTRONIC RECEIPTS OR SALES OR COMMERCIAL INVOICES, 
COLLECT TRANSACTION RECORDS, AND TRANSMIT THE SAME 
THROUGH THE DESIGNATED ELECTRONIC CHANNELS OF THE 
BUREAU IN THE STANDARD FORMAT REQUIRED subject to rules and 
regulations to be issued by the Secretary of Finance as recommended by 
the Commissioner of Internal Revenue: Provided, That the POINT OF SALE 
machines, VALUE-ADDED NETWORK TERMINALS, fiscal devices, and 
fiscal memory devices WITH CAPACITY TO MAKE SUCH TRANSMISSION 
shall be at the expense of the taxpayers[.]: PROVIDED FURTHER, THAT 
SUBJECT TO THE RULES AND REGULATIONS TO BE ISSUED BY THE 
SECRETARY OF FINANCE, THE COMMISSIONER MAY REQUIRE ANY 
TAXPAYER TO COMPLY WITH THE PROVISIONS OF THIS SECTION.
IN YEAR ONE (1) TO YEAR FOUR (4) OF THE IMPLEMENTATION 
PERIOD OF THIS ACT, A TAXPAYER WHO ADOPTS THE REQUIRED
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SYSTEM SHALL BE GRANTED A TAX CREDIT OF 0.1% OF THE
2 
PURCHASE VALUE, NET OF VALUE-ADDED TAX, FOR EVERY
3 
ELECTRONIC RECEIPT OR SALE OR COMMERCIAL INVOICE
4 
TRANSMITTED THROUGH THE DESIGNATED ELECTRONIC CHANNELS
5 
OF THE BUREAU AND ISSUED AN ELECTRONIC TAX TRANSACTION
6 
NUMBER.
7 
IN SUPPORT OF THE ELECTRONIC SALES REPORTING SYSTEM, THE
8 
BUREAU OF INTERNAL REVENUE MAY GRANT TAX INCENTIVES FOR
9 
ELECTRONICALLY TRACEABLE PAYMENTS IN THE FORM 
OF
10 
ALLOWABLE DEDUCTIBLE EXPENSE OF UP TO TEN PERCENT (10%)
11 
OF THE ELECTRONICALLY TRACEABLE PAYMENTS MADE BY THE
12 
TAXPAYER. AN ANNUAL LIMIT ON THE ALLOWED ELECTRONICALLY
13 
TRACEABLE PAYMENTS DEDUCTIBLE EXPENSE PER TAXPAYER MAY
14 
BE SET BY THE COMMISSIONER WITH THE APPROVAL OF THE
15 
SECRETARY OF FINANCE.
16 
ELECTRONICALLY TRACEABLE PAYMENTS 
REFER TO CREDIT CARD,
17 
DEBIT CARD, OR OTHER METHODS OF PAYMENT THAT CAN VERIFY
18 
THE IDENTITY OF PAYOR.
19 
THE BUREAU MAY LIKEWISE ESTABLISH A RECEIPT AND INVOICE
20 
LOTTERY PROGRAM FOR ELECTRONIC RECEIPTS OR SALES OR
21 
COMMERCIAL INVOICES TRANSMITTED THROUGH THE DESIGNATED
22 
ELECTRONIC CHANNELS OF THE BUREAU AND ISSUE A
23 
CORRESPONDING ELECTRONIC TAX TRANSACHON NUMBER.
24 
The data processing of sales and purchase data shall comply with the provisions
25 
of Republic Act No. 10173, otherwise known as the 'Data Privacy Acf and
26 
Section 270 of the NIRC, as amended, on unlawful divulgence of taxpayer
27 
information and such other laws relating to the confidentiality of information.
28 
XXX XXX XXX
29
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SEC. 55. Section 255 of the National Internal Revenue Code of 1997, as amended, is
31 
hereby amended to read as follows:
32
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"SEC. 255. Failure to File Return, Supply Correct and Accurate Information,
2 
Pay Tax, Withhold and Remit Tax and Refund Excess Taxes Withheld on
3 
Compensation. - Any person required under this Code or by rules and
4 
regulations promulgated thereunder to pay any tax, make a return, keep any
5 
record, or supply correct and accurate information, who willfully fails to pay
6 
such tax, make such return, keep such record, or supply such correct and
7 
accurate information, or withhold or remit taxes withheld, or refund excess
8 
taxes withheld on compensation, at the time or times required by law or rules
9 
and regulations shall, in addition to other penalties provided by law, upon
10 
conviction thereof, be punished by a fine of not less than [Ten thousand pesos
11 
(P10,000)] FORTY THOUSAND PESOS (P40,000) and [suffer] imprisonment
12 
of not less than one (1) year but not more than ten (10) years.
13 
Any person who attempts to make it appear for any reason that [he] THE TAX
14 
PAYER or another has in fact filed a return or statement, or actually files a
15 
return or statement and subsequently withdraws the same return or statement
16 
after securing the official receiving seal or stamp of receipt of an internal
17 
revenue office wherein the same was actually filed shall, upon conviction
18 
therefor, be punished by a fine of not less than [Ten thousand pesos (P10,000)
19 
but not more than Twenty thousand pesos (P20,000)] FORTY THOUSAND
20 
PESOS (P40/000) BUT NOT MORE THAN EIGHTY THOUSAND PESOS
21 
(P80f000) and [suffer] imprisonment of not less than one (1) year but not
22 
more than three (3) years.
23
24 
SEC. 56. Section 256 of the National Internal Revenue Code of 1997, as amended, is
25 
hereby amended to read as follows:
26 
"SEC. 256. Penal Liability of Corporations. - Any corporation, association or
27 
general co-partnership liable for any of the acts or omissions penalized under
28 
this Code, in addition to the penalties imposed herein upon the responsible
29 
corporate officers, partners, or employees shall, upon conviction for each act
30 
or omission, be punished by a fine of not less than [Fifty thousand pesos
31 
(P50,000) but not more than One hundred thousand pesos (P100,000)] TWO
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HUNDRED THOUSAND PESOS (P200,000) BUT NOT MORE THAN TWO
2 
MILLION EIGHT HUNDRED THOUSAND PESOS (P2,800,000).
3
4 
SEC. 57. Section 257 of the National Internal Revenue Code of 1997, as amended, is
5 
hereby amended to read as follows:
6
7 
"SEC. 257. Penal Liability for Making False Entries, Records or Reports, or Using
8 
Falsified or Fake Accountable Forms. -
9 
(A) Any financial officer or independent Certified Public Accountant engaged to
10 
examine and audit books of accounts of taxpayers under Section 232(A) and
11 
any person under his direction who:
12 
XXX 
XXX XXX
13 
(B) Any person who:
14 
(1) Not being an independent Certified Public Accountant according to Section
15 
232(B) or a financial officer, examines and audits books of accounts of
16 
taxpayers; or
17 
XXX 
XXX XXX
18 
(8) Willfully attempts in any manner to evade or defeat any tax imposed under
19 
this Code, or knowingly uses fake or falsified revenue official receipts, Letters
20 
of Authority, certificates authorizing registration. Tax Credit Certificates, Tax
21 
Debit Memoranda and other accountable forms shall, upon conviction for each
22 
act or omission, be punished by a fine of not less than [Fifty thousand pesos
23 
(P50,000) but not more than One hundred thousand pesos (P100,000)] ONE
24 
HUNDRED THIRTY THOUSAND PESOS (P130,000) BUT NOT MORE
25 
THAN TWO HUNDRED SEVENTY THOUSAND PESOS (P270f000) and
26 
[suffer] imprisonment of not less than two (2) years but not more than six (6)
27 
years.
28 
If the offender is a Certified Public Accountant, [his] THE OFFENDER'S
29 
[certificate as a Certified Public Accountant] LICENSE TO PRACTICE THE
30 
ACCOUNTING PROFESSION AND CERTIFICATE OF REGISTRATION
31 
shall be automatically revoked or cancelled upon conviction.
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In the case of foreigners, conviction under this Code shall result in [his] THEIR 
immediate deportation after serving sentence, without further proceedings for 
deportation.
SEC. 58. Section 258 of the National Internal Revenue Code of 1997, as amended, is
hereby amended to read as follows:
"SEC. 258. Unlawful Pursuit of Business. - Any person who carries on any 
business for which an annual registration fee is imposed without paying the tax 
as required by law shall, upon conviction for each act or omission, be punished 
by a fine of not less than [Five thousand pesos (P5,000) but not more than 
Twenty thousand pesos (P20,000)] FIFTY THOUSAND PESOS (P50,000) 
BUT NOT MORE THAN THREE HUNDRED THOUSAND PESOS 
(P300,000) and [suffer] imprisonment of not less than six (6) months but not 
more than two (2) years: Provided, That in the case of a person engaged in 
the business of distilling, rectifying, repacking, compounding or manufacturing 
any article subject to excise tax, [he] shall, upon conviction for each act or 
omission, be punished by a fine of not less than [Thirty thousand pesos 
(P30,000) but not more than Fifty thousand pesos (P50,000)] THREE 
HUNDRED THOUSAND PESOS (P300/000) BUT NOT MORE THAN 
SEVEN HUNDRED THOUSAND PESOS (P700,000) and [suffer] 
imprisonment of not less than two (2) years but not more than four (4) years.
SEC. 59. Section 261 of the National Internal Revenue Code of 1997, as amended, is
hereby amended to read as follows:
SEC. 261. Unlawful Use of Denatured Alcohol. - Any person who for the 
purpose of manufacturing any beverage, uses denatured alcohol or alcohol 
specially denatured to be used for motive power or withdrawn under bond for 
industrial uses or alcohol knowingly misrepresented to be denatured to be unfit 
for oral intake or who knowingly sells or offers for sale any beverage made in 
whole or in part from such alcohol or who uses such alcohol for the manufacture
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of liquid medicinal preparations taken internally, or knowingly sells or offers for
2 
sale such preparations containing as an ingredient such alcohol, shall, upon
3 
conviction for each act or omission be punished by a fine of not less than
4 
[Twenty thousand pesos (P20,000) but not more than One hundred thousand
5 
pesos (P100,000)] FIVE HUNDRED SIXTY THOUSAND PESOS
6 
(P560,000) BUT NOT MORE THAN TWO MILLION EIGHT HUNDRED
7 
THOUSAND (P2/800,000) and [suffer] imprisonment for a term of not less
8 
than six (6) years and one (1) day but not more than twelve (12) years."
9 
XXX XXX XXX 
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SEC. 60. Section 263 of the National Internal Revenue Code of 1997, as amended, is
12 
hereby amended to read as follows:
13
14 
"SEC. 263. Unlawful Possession or Removal of Articles Subject to Excise Tax
15 
without Payment of the Tax. - Any person who owns and/or is found in
16 
possession of imported articles subject to excise tax, the tax on which has not
17 
been paid in accordance with law, or any person who owns and/or is found in
18 
possession of imported tax-exempt articles other than those to whom they are
19 
legally issued shall be punished by:
20 
(a) X X X
21 
XXX XXX XXX
22 
(E) A FINE OF NOT LESS THAN ONE MILLION FIVE HUNDRED
23 
THOUSAND PESOS (Pl,500,000) BUT NOT MORE THAN FIFTEEN
24 
MILLION PESOS (PI5,000,000), AND IMPRISONMENT OF NOT LESS
25 
THAN SIX (6) YEARS AND ONE (1) DAY BUT NOT MORE THAN TWELVE
26 
(12) YEARS, IF THE APPRAISED VALUE, TO BE DETERMINED IN THE
27 
MANNER PRESCRIBED IN THE CUSTOMS MODERNIZATION AND
28 
TARIFF ACT, INCLUDING DUTIES AND TAXES, OF THE ARTICLES IS
29 
MORE THAN FIVE MILLION PESOS (P5,000,000) BUT NOT MORE
30 
THAN FIFTY MILLION PESOS (P50,000,000);
31 
(F) A FINE OF NOT LESS THAN FIFTEEN MILLION PESOS
32 
(P15,000,000) BUT NOT MORE THAN FIFTY MILLION PESOS
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(P50f000,000), AND IMPRISONMENT OF NOT LESS THAN TWELVE
2 
(12) YEARS AND ONE (1) DAY BUT NOT MORE THAN TWENTY (20)
3 
YEARS, IF THE APPRAISED VALUE, TO BE DETERMINED IN THE
4 
MANNER PRESCRIBED IN THE CUSTOMS MODERNIZATION AND
5 
TARIFF ACT, INCLUDING DUTIES AND TAXES, OF THE ARTICLES IS
6 
MORE THAN FIFTY MILLION PESOS (P50,000,000) BUT NOT MORE
7 
THAN TWO HUNDRED MILLION PESOS (P200,000,000); OR
8 
(G) A FINE OF NOT LESS THAN FIFTY MILLION PESOS (P50,000,000)
9 
AND IMPRISONMENT OF TWENTY (20) YEARS AND ONE (1) DAY BUT
10 
NOT MORE THAN THIRTY (30) YEARS, IF THE APPRAISED VALUE OF
11 
THE GOODS UNLAWFULLY IMPORTED TO BE DETERMINED IN THE
12 
MANNER PRESCRIBED IN THE CUSTOMS MODERNIZATION AND
13 
TARIFF ACT, INCLUDING DUTIES AND TAXES, EXCEEDS TWO
14 
HUNDRED MILLION PESOS (P200,000,000) OR IF THE AGGREGATE
15 
AMOUNT OF THE APPRAISED VALUE OF THE GOODS WHICH ARE THE
16 
SUBJECT OF UNLAWFUL IMPORTATION COMMITTED IN MORE THAN
17 
ONE INSTANCE, INCLUDING DUTIES AND TAXES, EXCEEDS TWO
18 
HUNDRED MILLION PESOS 
(P200,000,000).
19 
XXX XXX XXX
20
21 
SEC. 61. Section 264 of the National Internal Revenue Code of 1997, as amended, is
22 
hereby amended to read as follows:
23
24 
"SEC. 264. Failure or Refusal to Issue Receipts or Sales or Commercial Invoices,
25 
Violations Related to the Printing of such Receipts or Invoices and Other
26 
Violations. -
27 
(a) Any person who, being required under Section 237 to issue receipts or
28 
sales or commercial invoices, fails or refuses to issue such receipts or invoices,
29 
issues receipts or invoices that do not truly reflect and/or contain all the
30 
information required to be shown therein, or uses multiple or double receipts
31 
or invoices, shall, upon conviction for each act or omission, be punished by a
32 
fine of not less than [One thousand pesos (P1,000) but not more than Fifty
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thousand pesos (P50,000)] THIRTY THOUSAND PESOS (P30/000) BUT 
NOT MORE THAN ONE MILLION FOUR HUNDRED THOUSAND PESOS 
(Pl,400f000) and [suffer] imprisonment of not less than two (2) years but 
not more than four (4) years.
XXX XXX XXX
SEC. 62. Section 266 of the National Internal Revenue Code of 1997, as amended, is 
hereby amended to read as follows:
"SEC. 266. Failure to Obey Summons. - Any person who, AFTER HAVING 
BEEN [being] duly summoned to appear to testify, or to appear and produce 
books of accounts, records, memoranda or other papers, or to furnish 
information as required under the pertinent provisions of this Code, neglects to 
appear or to produce such books of accounts, records, memoranda or other 
papers, or to furnish such information, shall, upon conviction, be punished by 
a fine of not less than [Five thousand pesos (P5,000)] ONE HUNDRED 
THOUSAND PESOS (P100,000) but not more than [Ten thousand pesos 
(P10,000)] THREE HUNDRED THOUSAND PESOS (P300,000) and [suffer] 
imprisonment of not less than one (1) year but not more than two (2) years.
SEC. 63. A new section. Section 270-A is hereby inserted in the NIRC, as amended, 
and shall read as follows:
SEC. 270-A. OFFENSES RELATING TO EXCHANGES OF INFORMATION. 
~ VIOLATIONS OF THE PROVISIONS OF SECTION 6(F)(3) SHALL BE 
PUNISHABLE AS FOLLOWS:
(A) ANY OFFICER, OWNER, AGENT, MANAGER, DIRECTOR OR 
OFFICER-IN-CHARGE OF ANY REPORTING FINANCIAL INSTITUTION 
WHO FAILS TO SUPPLY FINANCIAL ACCOUNT INFORMATION WHEN 
REQUIRED OR REQUESTED UNDER THIS ACT AND ITS RULES AND 
REGULATIONS SHALL BE SUBJECT TO A FINE OF NOT LESS THAN ONE 
HUNDRED THOUSAND PESOS (P100,000.00), BUT NOT MORE THAN
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FIVE HUNDRED THOUSAND PESOS (P500,000.00), OR SUFFER
2 
IMPRISONMENT OF NOT LESS THAN SIX (6) MONTHS BUT NOT MORE
3 
THAN FOUR (4) YEARS, OR BOTH;
4 
(B) NOTWITHSTANDING SECTION 253(D) OF THIS CODE, ANY
5 
FINANCIAL INSTITUTION COVERED UNDER THE RULES AND
6 
REGULATIONS MADE UNDER THIS ACT WHICH FAILS TO:
7 
(1) REPORT THE INFORMATION AS AND WHEN REQUIRED UNDER
8 
THE RULES AND REGULATIONS MADE UNDER THIS ACT;
9 
(2) COMPLY WITH ANY OF THE DUE DILIGENCE OBLIGATIONS AS
10 
PRESCRIBED UNDER THE RULES AND REGULATIONS MADE UNDER
11 
THIS ACT; AND
12 
(3) FILE AND KEEP THE RECORDS REQUIRED WITHIN THE PURVIEW
13 
OF THIS ACT OR THE RULES AND REGULATIONS MADE UNDER THIS
14 
ACT SHALL BE PUNISHED, PER OMISSION, BY A FINE OF NOT LESS
15 
THAN FIFTY THOUSAND PESOS (P50,000) BUT NOT MORE THAN ONE
16 
HUNDRED THOUSAND PESOS (P100,000).
17 
(C) ANY OFFICER, OWNER, AGENT, MANAGER, DIRECTOR OR
18 
OFFICER-IN-CHARGE OF A REPORTING FINANCIAL INSTITUTION
19 
WHO FAILS TO FILE AND KEEP THE RECORDS REQUIRED WITHIN
20 
THE PURVIEW OF THIS ACT, SHALL BE SUBJECT TO A FINE NOT LESS
21 
THAN ONE HUNDRED THOUSAND PESOS (PHP100,000), BUT NOT
22 
MORE THAN FIVE HUNDRED THOUSAND PESOS (PHP500,000), OR
23 
SUFFER IMPRISONMENT OF NOT LESS THAN SIX (6) MONTHS BUT
24 
NOT MORE THAN ONE (1) YEAR, OR BOTH;
25 
(D) ANY OFFICER, OWNER, AGENT, MANAGER, DIRECTOR OR
26 
OFFICER-IN-CHARGE OF A REPORTING FINANCIAL INSTITUTION
27 
WHO SHALL BE NON-COMPLIANT WITH ANY OF THE DUE DILIGENCE
28 
OBLIGATIONS SHALL BE SUBJECT TO A FINE NOT LESS THAN ONE
29 
HUNDRED THOUSAND PESOS (PHP100,000), BUT NOT MORE THAN
30 
FIVE HUNDRED THOUSAND PESOS (PHP500,000), OR SUFFER
31 
IMPRISONMENT OF NOT LESS THAN SIX (6) MONTHS BUT NOT MORE
32 
THAN ONE (1) YEAR, OR BOTH; AND
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(E) ANY PERSON WHO MAKES A FALSE STATEMENT OR OMISSION IN 
RESPECT OF ANY INFORMATION REQUIRED TO BE REPORTED OR 
FURNISHED TO A FINANCIAL INSTITUTION FOR THE PURPOSES OF 
THE DUE DILIGENCE PROCEDURES UNDER THE RULES AND 
REGULATIONS MADE UNDER THIS ACT, SHALL BE SUBJECT TO A FINE 
OF NOT LESS THAN ONE HUNDRED THOUSAND PESOS (PHP100,000) 
BUT NOT MORE THAN FIVE HUNDRED THOUSAND PHILIPPINE PESOS 
(P500,000) FOR EACH SUCH FAILURE, OR SUFFER IMPRISONMENT 
OF SIX (6) MONTHS TO FOUR (4) YEARS IMPRISONMENT, OR BOTH.
IF A PERSON OR FINANCIAL INSTITUTION ENTERS INTO ANY 
ARRANGEMENT OR TAKES ANY ACTION, THE MAIN PURPOSE, OR ONE 
OF THE MAIN PURPOSES OF WHICH IS TO AVOID ANY OBLIGATION 
UNDER, OR TO CIRCUMVENT THE APPLICATION OF SECTION 6(F)(3), 
THE COMMISSIONER SHALL NOTIFY SUCH PERSON OR FINANCIAL 
INSTITUTION THAT THE ACCOUNTS COVERED BY SUCH 
ARRANGEMENT OR ACTION FALLS UNDER SECTION 6(F)(3) AS IF THE 
ARRANGEMENTS HAD NOT BEEN ENTERED INTO OR THE ACTION HAD 
NOT BEEN TAKEN, AND DIRECT THE REPORTING THEREOF.
SEC. 64. Section 275 of the National Internal Revenue Code of 1997, as amended, is
hereby amended to read as follows:
SEC. 275. Violation of Other Provisions of this Code or Rules and Regulations 
in General. - Any person who violates any provision of this Code or any rule or 
regulation promulgated by the Department of Finance, for which no specific 
penalty is provided by law, shall, upon conviction for each act or omission, be 
punished by a fine of not more than [One thousand pesos (P1,000)] THIRTY 
THOUSAND PESOS (P30,000) or [suffer] imprisonment of not more than [six 
(6) months,] TWO (2) YEARS, or both.
SEC. 65. Implementing Rules and Regulations. - The Department of Finance, in
consultation with the Securities and Exchange Commission, Bangko Sentral ng
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Pilipinas, Insurance Commission, the Bureau of the Treasury, and the Bureau of
2 
Internal Revenue, shall issue rules and regulations for the effective implementation of
3 
this Act.
4
5 
SEC. 66. Separability Clause. - If, for any reason any article or provision of this Act,
6 
or any portion thereof, or application of such article, provision, or portion thereof to
7 
any person, group, or circumstance is declared invalid or unconstitutional, the
8 
remainder of this Act shall not be affected by such decision or declaration.
9
10 
SEC. 67. Repealing Clause. - The following laws or provisions of laws are hereby
11 
repealed or modified accordingly and the persons and/or transactions affected herein
12 
are hereby made subject to applicable taxes on interest income, dividends, and capital
13 
gains, gross receipts tax, premium tax, and documentary stamp tax under the National
14 
Internal Revenue Code of 1997, as amended:
15 
(a) Section 9, insofar as the tax exemption on the issuance of bonds and
16 
securities is concerned, 
of Presidential Decree No. 1648, 
known 
as
17 
"Reorganizing the National Development Company and Establishing a Revised
18 
Charter Therefor";
19 
(b) Sections 6, 7, and 8, insofar as the tax exemptions on interest income,
20 
capital gains, and documentary stamp tax and on the issuance of bonds are
21 
concerned, of Executive Order No. 603, entitled "Creating a Light Rail Transit
22 
Authority, Vesting the Same with Authority to Construct and Operate the Light
23 
Rail Transit (LRT) Project and Providing Funds Therefor";
24 
(c) Section 14, insofar as tax exemption on interest income, capital gains, and
25 
documentary stamp tax is concerned, of Republic Act No. 7354, entitled "An
26 
Act Creating the Philippine Postal Corporation, Defining Its Powers, Functions
27 
and Responsibilities, Providing for Regulation of the Industry and for Other
28 
Purposes Connected Therewith";
29 
(d) Section 12, insofar as the tax exemptions on interest income, capital gains,
30 
and documentary stamp tax and on the issuance of bonds are concerned, of
31 
Republic Act No. 4850, entitled "An Act Creating the Laguna Lake Development
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Authority, Prescribing its Powers, Functions and Duties, Providing Funds
2 
Therefor, and for Other Purposes";
3 
(e) Number 8, insofar as tax exemption on interest income, capital gains, and
4 
documentary stamp tax is concerned, of Presidential Decree No. 37, entitled
5 
"Creating the Nayong Pilipino Foundation";
6 
(f) Section 12, insofar as tax exemption on interest income, capital gains, and
7 
documentary stamp tax is concerned, of Presidential Decree No. 205, entitled
8 
"Creating and Establishing the Development Academy of the Philippines,
9 
Defining its Powers, Functions, and Responsibilities, and for Other Purposes";
10 
(g) Article 202, insofar as tax exemption on interest income, capital gains,
11 
documentary stamp tax, and premium tax is concerned, of Presidential Decree
12 
No. 442 as amended by Presidential Decree No. 626, entitled "Labor Code of
13 
the Philippines";
14 
(h) Sections 10 and 11, insofar as the tax exemptions on interest income,
15 
capital gains, and documentary stamp tax of subsidiaries of Philippine
16 
Aerospace Development Corporation and on the issuance of bonds are
17 
concerned, of Presidential Decree No. 696, entitled "Revising Presidential
18 
Decree No. 286, dated September 5, 1973, as amended, otherwise known as
19 
The Charter of The Philippine Aerospace Development Corporation and for
20 
Other Purposes";
21 
(i) Section 2(g), insofar as the tax exemptions on interest income and on the
22 
issuance of bonds are concerned, of Republic Act No. 85, as amended by
23 
Republic Act No. 2081, entitled "An Act Creating the Rehabilitation Finance
24 
Corporation";
25 
0) Sections 76, 77 and 98, insofar as tax exemption on interest income,
26 
dividends, capital gains, and documentary stamp tax on bonds is concerned, of
27 
Republic Act No. 3844 otherwise known as "The Agricultural Land Reform
28 
Code";
29 
(k) Section 37, insofar as the tax exemption on interest income, capital gains,
30 
gross receipts tax, and documentary stamp tax is concerned, of Republic Act
31 
No. 6848 or The Charter of The Al-Amanah Islamic Investment Bank of the
32 
Philippines";
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(I) Sections 19, insofar as the tax exemptions on interest income and issuance
2 
of bonds are concerned, of Republic Act No. 3591, as amended by Republic Act
3 
No. 9576 or entitled as "An Act Increasing the Maximum Deposit Insurance
4 
Coverage, and in Connection Therewith, to Strengthen the Regulatory and
5 
Administrative Authority, and Financial Capability of the Philippine Deposit
6 
Insurance Corporation (PDIC), Amending for this Purpose Republic Act
7 
Numbered Three Thousand Five Hundred Ninety-One, as amended, otherwise
8 
known as The PDIC Charter, and for Other Purposes";
9 
(m) Section 12, insofar as tax exemption on interest income, capital gains, and
10 
documentary stamp tax and the issuance of bonds are concerned, of Executive
11 
Order No. 1037, entitled "An Act Creating the Philippine Retirement Park
12 
System, Providing Funds Therefor and for Other Purposes";
13 
(n) Sections 5 and 19, insofar as the tax exemptions on the issuance of bonds,
14 
interest income and documentary stamp tax are concerned, of Republic Act No.
15 
8763 or Home Guaranty Corporation Act of 2000;
16 
(o) Sections 19 and 25, insofar as tax exemption on documentary stamp tax is
17 
concerned, of Republic Act No. 7279 otherwise known as "The Urban
18 
Development and Housing Act of 1992";
19 
(p) Section 8(a), insofar as tax exemption on interest income, capital gains,
20 
and documentary stamp tax of bonds is concerned, as provided under Section
21 
1 of Republic Act No. 6395 or An Act Revising the Charter of the National Power
22 
Corporation;
23 
(q) Sections 9 and 15, insofar as the tax exemptions on the issuance of bonds,
24 
interest income, capital gains, and documentary stamp tax are concerned, of
25 
PD No. 334, entitled "Creating the Philippine National Oil Company, Defining its
26 
Powers and Functions, Providing Funds Therefore, and for Other Purposes";
27 
(r) Section 16, insofar as tax exemption on interest income, capital gains, and
28 
documentary stamp tax is concerned, of Presidential Decree No. 1467, entitled
29 
"An Act Creating the Philippine Crop Insurance Corporation, Prescribing Its
30 
Powers and Activities, Providing or Its Capitalization and for the Required
31 
Government Premium Subsidy, and for Other Purposes";
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(s) Section 3, insofar as the tax exemption on interest income, capital gains, 
and documentary stamp tax of bonds is concerned, of Republic Act No. 3601, 
entitled "An Act Granting the National Irrigation Administration";
(t) Section 6 (a, xviii(2)), in so far as tax exemption on interest income and 
documentary stamp tax is concerned, of Presidential Decree No. 1485, as 
amended by Presidential Decree No. 1770, entitled "Reconstituting the National 
Grains Authority to the National Food Authority, Broadening its Functions and 
Powers and for Other Purposes";
(u) Section 5(e), insofar as tax exemption on interest income, capital gains, 
and documentary stamp tax on bonds is concerned, of Republic Act No. 6260, 
entitled "An Act Instituting a Coconut Investment Fund and Creating a Coconut 
Investment Company for the Administration Thereof";
(v) Section 7, insofar as tax exemption on documentary stamp tax and premium 
tax is concerned, of Republic Act No. 7111, entitled "An Act Establishing The 
Overseas Workers' Investment Fund to Provide Incentives to Overseas 
Workers, Reduce the Foreign Debt Burden and for Other Purposes";
(w) Section 56, insofar as tax exemption on interest income, capital gains, and 
documentary stamp tax is concerned, of Republic Act No. 10801, entitled "An 
Act Governing the Operations and Administration of the Overseas Workers 
Welfare Administration";
(x) Section 5, insofar as tax exemption on interest income is concerned, of 
Republic Act No. 8367, entitled "An Act Providing for the Regulation of the 
Organization and Operation of Non-Stock Savings and Loan Associations";
(y) Section 28, insofar as tax exemption on capital gains on shares of stock and 
documentary stamp tax is concerned, of Republic Act No. 9267 or The 
Securitization Act of 2004";
(z) Section 15, insofar as tax exemption on capital gains and documentary 
stamp tax is concerned, of Republic Act No. 9182, as amended by Republic Act 
No. 9343, entitled "An Act Granting Tax Exemptions and Fee Privileges to 
Special Purpose Vehicles which Acquire or Invest in Non-Performing Assets, 
Setting the Regulatory Framework Therefor, and for Other Purposes";
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(aa) Section 23, insofar as no deduction from gross income shall be allowed in 
respect of any interest if the indebtedness is incurred to finance petroleum 
exploration is concerned, of Presidential Decree No. 87, entitled "Amending 
Presidential Decree No. 8 issued on October 2, 1972, and Promulgating an 
Amended Act to Promote the Discovery and Production of Indigenous 
Petroleum and Appropriate Funds Therefor";
(cc) Section 6, insofar as tax exemption on interest income, dividends and 
capital gains are concerned, of Republic Act No. 6426 or the Foreign Currency 
Deposit Act of the Philippines, as amended;
(bb) Section 32, insofar as the tax exemptions on capital gains, interest income 
and DST and issuance of bonds are concerned, of Republic Act No. 6424 or the 
Philippine Export Credit Insurance and Guarantee Corporation Act;
(dd) Section 16(b), insofar as tax exemption on interest income, dividends and 
capital gains are concerned, of Republic Act No. 9497, entitled "An Act Creating 
the Civil Aviation Authority of the Philippines, Authorizing the Appropriation of 
Funds Therefor, and For Other Purposes";
(ee) Section 21, insofar as tax exemption on interest income, dividends and 
capital gains are concerned, of Republic Act No. 7356, entitled "An Act Creating 
the National Commission for Culture and the Arts, Establishing National 
Endowment Fund for Culture and the Arts, and For Other Purposes";
(ff) Section 23 (a), insofar as tax exemption on interest income, dividends and 
capital gains are concerned, of Republic Act No. 10086, entitled "An Act 
Strengthening Peoples' Nationalism through Philippine Flistory by Changing the 
Nomenclature of the National Historical Institute into the National 
Historical Commission of the Philippines, Strengthening Its Powers and 
Functions, and For Other Purposes";
(gg) Section 11, insofar as tax exemption on interest income, dividends and 
capital gains are concerned, of Presidential Decree No. 1201, series of 1977, 
entitled "Creating the Philippine Institute for Development Studies";
(hh) Section 11, insofar as tax exemption on interest income, dividends and 
capital gains are concerned, of Republic Act No. 2640, as amended by Batas 
Pambansa Bilang 35, entitled "An Act to Create A Public Corporation to be
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Known as the Veterans Federation of the Philippines, Defining its Powers, and 
for Other Purposes"; and
(ii) Section 12, insofar as tax exemption on interest income, dividends and 
capital gains are concerned, of Republic Act No. 4356, as amended by Republic 
Act No. 6366, entitled "An Act Creating the Philippine National Railways, 
Prescribing Its Powers, Functions and Duties, and Providing for the Necessary 
Funds for Its Operation".
SEC. 68. Effectivity - This Act shall take effect on January 1, 2023, following its 
complete publication in the Official Gazette or in at least one (1) newspaper of general 
circulation.
Approved,
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