Republic of the Philippines 
HOUSE OF REPRESENTATIVES 
Constitution Hills, Quezon City 
TWENTIETH CONGRESS 
First Regular Session 
HOUSE BILL No. _________ 
Introduced by REPRESENTATIVE LORDAN G. SUAN 
EXPLANATORY NOTE 
The Tax Reform for Acceleration and Inclusion (TRAIN) law was passed in 2017 to 
rationalize the Philippines' tax system and meet the growing needs of its people. To 
achieve these goals, the law provides that an excise tax shall be imposed on domestic and 
imported coal. It stresses that said tax “shall be levied, assessed, and collected 
notwithstanding any incentives granted in any law or special law.” It specifically 
emphasized the word “notwithstanding,” which clearly means “in spite of,”“despite,” or 
“regardless of.”This is consistent with the general repealing clause provided in House Bill 
No. 5636, passed by the 17th Congress. Senate Bill No.1592, or the Senate’s version, 
however, only specified the laws, decrees, executive orders, and issuances that were being 
repealed under the VAT provisions of the NIRC. The outcome of the Bi-Cam report carried 
the Senate’s repeal clause, which became the TRAIN law we have to date. 
Whether deliberate or not, the omission of Presidential Decree No. 972 from the 
repealing provision of Republic Act 10963 failed to account for the social and 
environmental impact of the coal industry. It has long been benefiting from government 
subsidies despite its negative effects on the environment, agricultural productivity, and 
people’s health. The income tax it pays miserably compensates for the real cost. 
Additionally, this omission prevents the government from collecting billions of pesos, 
which could have been used to provide better health care and reliable public 
infrastructure.  
This bill seeks to plug the loophole in the TRAIN law that coal companies use to get 
away from their obligation and accountability. This bill’s amendment will enable the 
government to collect the necessary taxes to improve people’s productivity and address 
the environmental impact of coal extraction and consumption. 
In view of the foregoing, the immediate passage of this bill is earnestly sought. 
HON. LORDAN G. SUAN 
1st District 
Cagayan de Oro City 
August 20, 2025
2:33 pm
3910


Republic of the Philippines 
HOUSE OF REPRESENTATIVES 
Constitution Hills, Quezon City 
TWENTIETH CONGRESS 
First Regular Session 
HOUSE BILL No. _________ 
Introduced by REPRESENTATIVE LORDAN G. SUAN 
Be it enacted by the Senate and House of Representatives of the Philippines in Congress 
assembled: 
AN ACT  
AMENDING SECTION 86 OF REPUBLIC ACT 10963, OTHERWISE KNOWN AS THE TAX 
REFORM FOR ACCELERATION AND INCLUSION (TRAIN) 
SECTION 1. Section 86 of Republic Act 10963, otherwise known as the Tax Reform 
for Acceleration and Inclusion (TRAIN), is hereby amended to read as follows: 
Section 86. Repealing Clause. - The following laws or provisions of laws are hereby 
repealed, and the persons and/or transactions affected herein are made subject to the 
VAT provision of Title IV and Excise provisions of TITLE VI of the NIRC, as amended: 
(a)
x xx
(bbb) x xx 
Provided, That, with respect to income tax, the following laws or provisions of laws are 
hereby repealed or amended: 
x xx 
Provided, That, with respect to excise tax, Section 16 (a) of Presidential Decree No. 
972, or The Coal Development Act of 1976, as amended, is hereby repealed or 
amended. 
SECTION 2. Effectivity.This Act shall take effect fifteen (15) days from the date of 
its publication in the Official Gazette or a website provided for by law. 
Approved, 
3910