Republic of the Philippines
HOUSE OF REPRESENTATIVES
Quezon City
NINETEENTH CONGRESS
First Regular Session
HOUSE BILL No.  8113
Introduced by HON. AUGUSTINA D0IvllNIQUE "Ditse Tina" C. PANCHO
EXPLANATORY NOTE
It   is   the   declared   policy   of  the   State   to   protect  and   enhance   revenue
administration and collection, and make the country's tax system more equitable,  by
simplifying the tax compliance requirements. In support of this, RA 11213, entitled "An
Act Enhancing Revenue Administration and Collection by Granting an Amnesty on All
Unpaid  Internal  Revenue  Taxes  Imposed  by  the  National  Government for Taxable
Year 2017 and Prior Years with Respect to Estate Tax, Other Internal Revenue Taxes,
and Tax on Delinquencies" was enacted in 2018 to give reasonable tax relief to estates
with deficiency estate taxes.
However, the scourge of the 2019 Corona Virus Pandemic drastically affected
all facets of our society and had an unprecedented negative impact on our economy.
In response government implemented emergency legislation for stimulus measures to
help alleviate the  burden  the  pandemic has  brought on  businesses,  individuals and
families alike.
The  pandemic  also  severely  includes  taxpayers'  capacity  to  settle  their  tax
liabilities,  including  the  availment  of the  deadlines  as  provided  by  RA  11213  in  the
years from 2019 onwards.  In  line with this reality, there now exists need to re-design
our tax  policies  in  order to  deliver a  balance  of equity,  growth  and  sustainability.  A
return  to  "business  as  usual"  will  not  suffice  as,  in  addition  to  the  aforementioned
impacts of the pandemic, majority of our people continue to confront other challenges
such as rising inequalities, inadequate social safety nets, and unequal access to health
care and to digital infrastructure.
Within  this  context,  we  now  see  a  need  to  amend  current  provisions  in  RA
11213 in order to responsively address challenges to taxpayers' capacity to settle their
tax liabilities, and grant relief by expanding the due dates for tax filings and payments.
This Bill seeks to address this urgent problem.
First it seeks to amend the date within which to avail, not only of the estate tax
amnesty,  but  the  amnesty  on  all  unpaid  Internal  Revenue  Taxes  imposed  by  the
National   Government   and   tax   on   delinquencies   be   extended   from   June   14,
2021 (pursuant to RA 11213) to June 14, 2025 to provide relief to taxpayers who were
not able to avail of the benefits of the tax amnesty act in view of the financial difficulty


brought  about  by  the  pandemic  during  the  year  2019  up  to  2022.  Further this  Bill
proposes that the period of coverage of the tax amnesties for estate tax,  all  unpaid
internal revenue taxes and tax on delinquencies (pursuant to RA 11213) be expanded
from "2017 and prior years" to "2022 and prior years".
These proposed amendments for this Bill intend to provide relief to taxpayers
on the penalties which may have been incurred for:
1.   Failure to pay the estate tax (for deaths caused or during the pandemic),
2nd  District,  Bulacan


Republic of the Philippines
HOUSE OF REPRESENTATIVES
Quezon City
NINETEENTH CONGRESS
First Regular Session
HOUSE BILL NO. 8113
Introduced by HON. AUGUSTINA DOMINIQUE "Ditse Tina" C. PANCHO
"AN ACT EXPANDING THE ESTATE TAX AMNESTY AND FOR OTHER
PURPOSES, AMIVIENDING SECTIONS 4, 6, 8, 9,10,11,12,15,17, and  19,
FURTHER AMENDING REPUBLIC ACT NO.11213, AS AMENDED BY
REPUBLIC ACT NO.11569, OTHERWISE KNOWN AS THE "TAX AMNESTY
ACT„
Be it enacted by the Senate and House of Representatives of the Philippines in
Congress assembled:
SECTloN  1.  -The Title  of Republic Act  No.11569,  otherwise  known  as the  "Tax
Amnesty Act" is hereby amended to read as follows:
"An  Act  Enhancing  Revenue  Administration  and  Collection  by  Granting  an
Amnesty on All Unpaid Internal Revenue Taxes Imposed by the National Government
for  Taxable  Year  [2017]  2022  and  Prior  Years  with  Respect  to  Estate  Tax,  Other
Internal Revenue Taxes, and Tax on Delinquencies"
SEC. 2. Section 4 of the same Act is hereby amended to read as follows:
``Sec.  4.  Coverage. - There is  hereby authorized  and  granted  a tax amnesty,
hereinafter called Estate Tax Amnesty, which shall cover the estate of decedents who
died on or before December 31, [2017] 2022, with or without assessments duly issued
therefor, whose estate taxes have remained unpaid or have accrued as of December
31, [2017] 2022: Prov/.ded, however, That the Estate Tax Amnesty hereby authorized
and granted shall not cover instances enumerated under Section 9 hereof."
SEC. 3. Section 6 of the same Act is hereby amended to read as follows:
``Sec. 6. Availment of the  Estate Tax  Amnesty; When  and Where to File and
Pay. -  The  executor  or  administrator  of  the  estate,  or  jf  there  is  no  executor  or
administrator appointed, the legal heirs, transferees or beneficiaries, who wish to avail
of the  Estate Tax Amnesty shall,  [within  June  15,  2021  until  June 24,  2023]  UNTIL
JUNE 14, 2025, file with the Revenue District Office of the Bureau of Internal Revenue,
which  has jurisdiction  over the  last residence  of the decedent,  a sworn  Estate Tax
Amnesty Return, in such forms as may be prescribed in the lmplementing Rules and
Regulations."


XXX
SEC. 4. Section 8 of the same Act is hereby amended to read as follows:
"Sec.   8. /mmun/.i/.es  and  Pr/.v/./eges. -   Estates  covered   by  the   Estate  Tax
Amnesty, which have fully complied with all the conditions set forth in this Act, including
the payment of the estate amnesty tax shall be immune from the payment of all estate
taxes, as well as any increments and additions thereto, arising from the failure to pay
any and  all  estate taxes for taxable year [2017] 2022  and  prior years,  and  from  all
appurtenant civil, criminal, and administrative cases and penalties under the National
Internal Revenue Code of 1997, as amended."
XXX
SEC. 5. Section 9 of the same Act is hereby amended to read as follows:
"Section 9. Except/ons. -The Estate Tax Amnesty under Title 11 of this Act shall
not extend to  PROPERTIES WITH  estate tax cases which  shall  have  become final
and executory and to properties involved in cases pending in appropriate courts:"
XXX
SEC. 7. Section 10 of the same Act is hereby amended to read as follows:
"Sec.10. Coverage. -There is hereby authorized and granted a tax amnesty,
hereinafter  called   General  Tax  Amnesty,   which,   shall   cover  all   national   internal
revenue taxes such  as,  but not limited  to,  income tax,  withholding  tax,  capital gains
tax. donor's tax, value-added tax, other percentage taxes, excise tax and documentary
stamp tax collected by the Bureau of Internal Revenue, including value-added tax and
excise taxes collected  by the  Bureau  of Customs for taxable year [2017]  2022  and
prior years,"
XXX
SEC. 8. Section 11  of the same Act is hereby amended to read as follows:
"See.   11. Entitlement   Under  the   General   Tax   Amnesty. -   Exicep+  for  the
instances covered in Section 16 hereof, any person] whether natural orjuridical, may
enjoy the  immunities  and  privileges  of the  General  Tax Amnesty  by  paying,  at the
taxpayers option, an amnesty tax at:
(i)  the  rate  of two  percent  (20/o)  based  on  the  taxpayer's  total  assets  as  of
December 31, [2017] 2022, as declared in the Statement of Total Assets; or
(ii) based on the taxpayer's total networth as of December 31, [2017] 2022, as
declared in the Statement of Assets,  Liabilities, and  Networth filed pursuant to
Section  12  hereof and  in  accordance with the following  schedule of amnesty
tax rates and minimum amnesty tax payments required:
XXX


(c) Other juridical entities, including, but not limited to, cooperatives and
foundations, that have become taxable as of December 31, [2017] 2022 ......... 5% or
P75,000, whichever is higher:"
XXX
SEC. 9. Section 12 of the same Act is hereby amended to read as follows:
"Sectiron 12. Availment of the General Tax Amnesty; When and. Where to File
and Pay. -Any  person,  natural  or juridical,  who wishes to avail  of the  General  Tax
Amnesty shall, [within one (1 ) year from the effectivity of the lmplementing Rules and
Regulations]  UNTIL JUNE  14, 2025, file with the appropriate office of the Bureau of
Internal  Revenue,  which  has jurisdiction  over  the  taxpayer,  a  sworn  General  Tax
Amnesty Return accompanied by a notarized Statement of Total Assets or notarized
Statement of Asssets,  Liabilities, and Networth, as the case maybe, as of December
31,  [2017] 2022.
XXX
SEC.10. Section 13 of the same Act is hereby amended to read as follows:
"See.13. Contents of the Statement of Total Assets and. Statement of Assets,
Liabilities, and Networfh. -
(A) The Statement of Total Assets shall contain a declaration of the total assets
as of December 31, [2017] 2022, as follows:"
XXX
(8) The Statement of Assets,  Liabilities, and Networth shall contain a true and
complete declaration of assets, liabilities, and networth of the taxpayer as of December
31,  [2017] 2022,  as follows:"
XXX
SEC. 11. Section 15 of the same Act is hereby amended to read as follows:
"Sec.  15. /mmun/I/.es  and  Pr/.v/./eges. -Those  who  avail  of the  General  Tax
Amnesty and have fully complied with all the conditions set forth in this Act and upon
payment of the amnesty tax shall be entitled to the following immunities and privileges:
(a) With respect to the years covered by the tax amnesty, the taxpayer shall be
immune from the payment of taxes,  as well as additions thereto,  and from all
appurtenant civil,  criminal,  and  administrative  cases  and  penalties  under the
National  Internal Revenue Code of 1997, as amended, arising from the failure
to pay any and all internal revenue taxes for taxable year [2017] 2022 and prior
years and from such other investigations or suits insofar as they relate to the
assets,  liabilities,  networth,  and  internal revenue taxes that are subject of the
tax amnesty."


XXX
SEC.12. Section 17 of the same Act is hereby amended to read as follows:
"Sec.17. Coverage. -There is hereby authorized and granted a tax amnesty
herein called the Tax Amnesty on Delinquencies, which shall cover all national internal
revenue taxes such  as,  but not limited to,  income tax,  withholding  tax,  capital gains
tax, donor's tax, value-added tax, other percentage taxes, excise tax and documentary
stamp tax collected by the Bureau of Internal Revenue, including value-added tax and
excise taxes collected  by the  Bureau  of Customs for taxable year [2017]  2022  and
prior years."
SEC.13. Section 19 of the same Act is hereby amended to read as follows:
``Sec. 19. Availment of the Tax Amnesty on  Delinquencies; When  and Where
fo  F/./e  and Pay. - Any  person,  natural  or juridical,  who  wishes  to  avail  of the  Tax
Amnesty  on   Delinquencies  shall,   [within  one  (1)  year  from  the  effectivify  of  the
lmplementing  Rules and  Regulations of this Act] UNTIL JUNE 14, 2025, file with the
appropriate office of the Bureau of Internal  Revenue, which  has jurisdiction over the
residence or principal  place of business  of the taxpayer,  a  sworn  Tax Amnesty  on
Delinquencies Return accompanied by a Certification of Delinquency."
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SEC. 14. Implementing  Rules and Regulations. - The Secrctary Of F.inance shall,  .in
coordination with the Commissioner of Internal  Revenue, promulgate and publish the
necessary rules and regulations of this Act within ninety (90) days from its effectivity.
The  failure  of  the  Secretary  of  Finance  to  promulgate  the  said  rules  and
regulations shall not prevent the implementation of this Act upon its effectivity.
SEC.15. Separab/.//.fy C/arse. -lf any portion or provision of this Act is declared
unconstitutional, the remainder of this Act or any provision not affected thereby shall
remain in force and effect.
SEC.16. Repea//.ng C/ause. -All other laws, acts, presidential decrees, executive
orders, issuances, presidential proclamations, rules and regulations, or parts thereof,
which  are  contrary  to  and  inconsistent  with  any  provision  of  this  Act  are  hereby
repealed, amended or modified accordingly.
SEC.17.  Effecf7-v/.fy C/arse. -This Act shall  take  effect fifteen  (15)  days  after its
publication in the Off/.c/.a/ Gazeffe or in a newspaper of general circulation.
Approved,