Bureau of Internal Revenue Issuances
REVENUE MEMORANDUM CIRCULAR
RMC No. 80-2025
August 28, 2025
Lost Sixty (60) Triplicate Copies of Used/Issued BIR Form No. 0535 – Taxpayer Information Sheet.
REVENUE MEMORANDUM ORDER
RMO No. 37-2025
August 27, 2025
Amending Annex – E (Calamity Leave) of Revenue Memorandum Order (RMO) No. 4-2021 Re: Consolidated Policies and Guidelines in the Monitoring of Attendance and Leave Management Amending RMO No. 28-2008, as amended by RMO No. 21-2011.
REVENUE DELEGATION AUTHORITY ORDERS
RDAO No. 45-2025
August 22, 2025
Designates the OIC-Assistant Commissioner of the Information Systems Project Management Service as Officer-in-Charge in view of the official travel of Information Systems Group’s Deputy Commissioner.
RDAO No. 46-2025
August 22, 2025
Designates the OIC-Assistant Commissioner of the Information Systems Project Management Service the authority to sign documents specified in the Order in view of the approved leave of absence of Information Systems Group’s Deputy Commissioner.
RDAO No. 47-2025
August 22, 2025
Designates the OIC-Assistant Commissioner of the Information Systems Project Management Service as Officer-in-Charge in view of the approved leave of absence of Information Systems Group’s Deputy Commissioner.
RDAO No. 48-2025
August 22, 2025
Designates the Assistant Commissioner of the Legal Service as Officer-in-Charge in view of the Official Travel of Legal Group’s Deputy Commissioner.
RDAO No. 49-2025
August 22, 2025
Delegates to the Chief Assessment Division the authority to sign documents specified in the Order in view of the approved leave of RR 6’s Asst. Regional Director.
TAX ADVISORY
The BIR shall conduct a Public Consultation on the Proposed Revenue Regulations regarding Guidelines and Procedures in Administering the Advance Pricing Arrangement Program on August 28, 2025 from 1:00PM to 5:00 PM at the BIR National Training Center, Quezon City and via Zoom
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https://bircdn.bir.gov.ph/BIR/pdf/Draft%20RR%20on%20APA_for%20public%20consultation.pdf
TAX LAW
REPUBLIC ACT No. 12214 – Capital Markets Efficiency Promotion Act (CMEPA)
BIR Website / signed May 29, 2025
AN ACT AMENDING SECTIONS 22, 24, 25, 27, 28, 32, 34, 38, 39, 42, 51, 52, 56, 57, 127, 149, 174, 176, 179, 190, 199, AND 258 OF REPUBLIC ACT NO. 8424, ОТHERWISE KNOWN AS THE NATIONAL INTERNAL REVENUE CODE OF 1997, AS AMENDED, AND FOR OTHER PURPOSES
REPUBLIC ACT No. 12079 – A VAT Refund for Non- Resident Tourists
Official Gazette / December 9, 2024
AN ACT CREATING A VAT REFUND MECHANISM FOR NON-RESIDENT TOURISTS, ADDING A NEW SECTION 112-A TO THE NATIONAL INTERNAL REVENUE CODE OF 1997, AS AMENDED, FOR THE PURPOSE
REPUBLIC ACT No. 12066 – CREATE MORE
Official Gazette / November 13, 2024
AN ACT AMENDING SECTIONS 27, 28, 32, 34, 57, 106, 108, 109, 112, 135, 237, 237-A, 269, 292, 293, 294, 295, 296, 297, 300, 301, 308, 309, 310, AND 311, AND ADDING NEW SECTIONS 135-A, 295-A, 296-A, AND 297-A OF THE NATIONAL INTERNAL REVENUE CODE OF 1997, AS AMENDED, AND FOR OTHER PURPOSES.
REPUBLIC ACT No. 12023 – VAT on Digital Services
Official Gazette / October 2, 2024
AN ACT AMENDING SECTIONS 105, 108, 109, 110, 113, 114, 115, 128, 236, AND 288 AND ADDING NEW SECTIONS 108-A AND 108-B OF THE NATIONAL INTERNAL REVENUE CODE OF 1997, AS AMENDED
TAX AND BUSINESS RELATED NEWS
BIR WEEKENDER BRIEFS
Volume No. 16 Issue No 35 Week ending August 29, 2025 – (BIR Website/ August 29, 2025)
BIR conducts Nationwide and Simultaneous filing of 75 Tax Evasion Cases against Illicit Vape Retailers/Sellers – On August 20, 2025, the Bureau of Internal Revenue (BIR), led by Commissioner Romeo D. Lumagui, Jr., filed 75 criminal complaints before the Department of Justice against various individuals and businesses involved in the illicit trade of vaporized nicotine and non-nicotine products (vape). These cases amounted a tax liability of ₱711.3 million. “Revenue regions from Luzon, Visayas, and Mindanao are filing their own local criminal cases right now. The BIR has proven thatit will file cases afterthe biggest illicit vape sellers such as Flava, Denkat, Flare, and Tap Fog due to the continuing disobedience of illicit vape retailers, they will suffer the same fate, ” Commissioner Lumagui stated. The nationwide filing was a result of the BIR’s continuous raids and inspections that uncovered the rampant selling of untaxed vape, including those without the required internal revenue stamps and proper BIR registration.
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https://bir-cdn.bir.gov.ph/BIR/pdf/v16n35.pdf
P8.6-B SMC shares not part of Marcos estate, CTA rules
Business World / Chloe Mari A. Hufana / August 24, 2025
THE Court of Tax Appeals (CTA) ordered the Bureau of Internal Revenue (BIR) to stop enforcing a 1991 Marcos estate tax assessment against P8.6 billion worth of San Miguel Corp. (SMC) shares registered under the late tycoon Eduardo M. Cojuangco, Jr. The tax court’s first division ruled the shares are Mr. Cojuangco’s exclusive property and not part of the Marcos estate, calling the BIR’s collection efforts “arbitrary, capricious, and whimsical.” It added the Bureau’s attempt to seize the stock placed unrelated shareholders at risk of being held liable for a tax obligation owed by a different taxpayer. “Respondent’s (BIR) unfounded persistence in pursuing collection against the Cojuangco SMC shares, despite their exclusion from the decedent’s estate, shows arbitrariness, capriciousness, and whimsicality, amounting to grave abuse of discretion,” the 60-page ruling released to the public on Aug. 14 read.
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https://www.bworldonline.com/the-nation/2025/08/24/693286/p8-6-b-smc-shares-not-part-of-marcos-estate-cta-rules/
The Advance Pricing Agreement: What it means for businesses ‘Let’s Talk Tax’
Business World / Paul Vinces C. Leorna / August 25, 2025
The Bureau of Internal Revenue (BIR) has announced that it will conduct a public consultation on the draft Revenue Regulations governing the Advance Pricing Agreement (APA) on Aug. 28, 2025. This marks a significant step forward in the Philippines’ efforts to modernize its transfer pricing framework and align with international best practices. The journey toward an APA regime has been long. In 2013, the BIR issued Revenue Regulations (RR) No. 2-2013, formally introducing the concept of APAs through its Transfer Pricing Guidelines. However, progress since then has been limited, with few public developments on APA implementation. Despite the delay, the BIR has taken several measures to strengthen transfer pricing compliance and safeguard the tax base against profit shifting. These include Revenue Audit Memorandum Order (RAMO) No. 1-2019, which established standardized audit procedures for related party and intra-firm transactions and RR No. 34-2020, along with its subsequent amendments, which require taxpayers to file BIR Form No. 1709 (Information Return on Related Party Transactions).
WHAT IS AN APA?
RR No. 2-2013 defines APA as a facility available to taxpayers engaged in cross-border transactions. It is an agreement entered into between the taxpayer and the BIR to determine in advance an appropriate set of criteria (e.g., transfer pricing method, comparables and appropriate adjustments thereto) to ascertain the transfer prices of controlled transactions over a fixed period. The purpose of an APA is to reduce the risk of transfer pricing examinations and double taxation.
WHAT’S IN IT FOR THE TAXPAYERS
The implementation of an APA program by the BIR offers Philippine taxpayers several meaningful benefits. First and foremost, it provides certainty and predictability in how transfer pricing methods will be treated, thus, helping businesses avoid unexpected tax assessments. By agreeing on pricing methods in advance, taxpayers can significantly reduce the risk of audits and adjustments. For multinational enterprises, APAs also help prevent double taxation, which ensures that income isn’t taxed more than once across jurisdictions. While the APA process requires upfront effort, it ultimately leads to lower compliance costs, as annual reporting becomes more streamlined and focused.
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https://www.bworldonline.com/economy/2025/08/25/693670/the-advance-pricing-agreement-what-it-means-for-businesses/
Online sellers hit additional fee charged by Shopee, Lazada
The Philippine Star / Raonier Allan Ronda / August 25, 2025 – MANILA, Philippines
Online sellers are restive over a new P5 “order processing fee” that e-commerce giants Shopee and Lazada will charge them starting Sept. 3. The online-based sellers have been airing their complaints and tagging the Department of Trade and Industry (DTI) in various Facebook forums over the weekend against the surprise new fee to be charged by the two online e-commerce giants. The additional fee on completed sales transactions is on top of the value-added tax (VAT) and other transaction fees already charged for each completed sales transaction that goes through the online stores of the two platforms. Currently, both Shopee and Lazada already impose a “service fee” and a “transaction fee” on all completed sales transactions by a merchant or online seller on their platform. There is also VAT of 10 to 12 percent slapped on each sale transaction, collected by the Bureau of Internal Revenue. Shopee Philippines posted a policy update dated Aug. 20 on its Seller Education Hub regarding the imposition of the P5 order processing fee.
“To support ongoing reinvestments in the platform and deliver long-term value to our seller community, Shopee will introduce a P5 Order Processing Fee starting Sept. 3, 2025,” Shopee Philippines said in their notice.
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https://www.philstar.com/headlines/2025/08/25/2467874/online-sellers-hit-additional-fee-charged-shopee-lazada
Empowering education through tax: Highlights of RR 13-2025 ‘Top of Mind’
The Philippine Star / Lily Nadia Copada / August 26, 2025
Education stands as one of the pillars of our nation, shaping individuals to become vital contributors to society – artists, educators, designers, lawyers, accountants and more. It is therefore essential that the state devote critical attention to the education system’s development for the benefit of future generations. To reinforce this commitment, the Philippine government enacted Republic Act 8525, or the Adopt-a-School Act of 1998, encouraging private entities to support public education through contributions, in exchange for tax incentives and exemptions. Over time, the Bureau of Internal Revenue (BIR) released several implementing rules, the latest of which is Revenue Regulations (RR) 13-2025. This consolidates the provisions of RA 8525, RA 12063 (Enterprise-Based Education and Training or EBET Framework Act), and prior regulations to streamline procedures for availing of tax privileges. RR 13-2025 grants incentives to qualified taxpayers, such as registered export and domestic enterprises, private entities and Technical-Vocational Institutions (TVIs), as determined upon application.
Registered export and domestic enterprises
In addition to the 50 percent additional deduction on labor expenses excluding salaries, wages, benefits and other personnel costs incurred for administrative, indirect labor and support services, these entities are entitled to a 100 percent additional deduction on qualified training expenses. This additional deduction must be supported by a certification from DepEd, CHED or TESDA, along with a sworn declaration issued by the applicant’s authorized officer as to the amount of expenses being deducted.
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https://www.philstar.com/business/2025/08/26/2468005/empowering-education-through-taxhighlights-rr-13-2025
BIR to conduct tax audit on anomalous flood control contractors
Philippine News Agency / August 26, 2025 – MANILA
Bureau of Internal Revenue (BIR) Commissioner Romeo Lumagui Jr. has directed the initiation of a tax fraud investigation targeting contractors involved in anomalous flood control projects, as identified by President Ferdinand R. Marcos Jr. Lumagui has instructed all BIR offices to closely monitor developments in the President’s investigation and conduct a parallel audit of the concerned contractors. “The BIR will undertake a parallel investigation of contractors implicated in irregular flood control projects. We will support the President’s crusade by auditing the tax returns and payments of these entities,” Lumagui said in a news release on Tuesday. “Should any contractor be found to have underpaid or evaded taxes, the BIR will not issue an updated tax clearance to them. The contractor will be disqualified from participating in future government procurements, and the final settlement of their existing government contracts will be suspended.” This directive aligns with the provisions of Revenue Regulation No. 17-2024 (RR No. 17-2024), which mandates that government contractors must secure an updated tax clearance from the BIR before the final settlement of any government contract.
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https://www.pna.gov.ph/articles/1257304
SC sets up new integrity office
Business World / Chloe Mari A. Hufana / August 26, 2025
THE Supreme Court (SC) on Tuesday approved the reorganization of the Judicial Integrity Board (JIB) into the Judicial Integrity Office (JIO) in a bid to strengthen accountability and streamline the handling of administrative disciplinary cases within the Judiciary. In a resolution penned by Justice Antonio T. Kho, Jr., the SC en banc adopted A.M. No. 23-12-05-SC, placing the JIO under the direct supervision and control of the High Court. The JIO will replace the five-member board with a single Judicial Integrity Officer, who will serve a four-year term and may be reappointed once. The officer must be at least 45 years old, have 15 years of legal practice, and possess investigative experience. The post carries a Salary Grade 30, Step 8 compensation.
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https://www.bworldonline.com/the-nation/2025/08/26/693917/sc-sets-up-new-integrity-office/
Hong Kong IPA touts low taxes, market access to PHL investors
Business World / Beatriz Marie D. Cruz / August 26, 2025
HONG KONG is touting its favorable tax regime and market access to attract investment from Philippine conglomerates, technology companies, and high net worth individuals. Invest Hong Kong (InvestHK), the city’s investment promotion agency (IPA), added that the Philippines “also has a lot of wealthy family businesses, large conglomerates. So, when they want to plan for their wealth management, traditionally, a lot of them have done in Singapore, but they know about Hong Kong now,” Alpha Lau, director-general of investment promotion at InvestHK, said at a media roundtable on Tuesday.
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https://www.bworldonline.com/economy/2025/08/26/693903/hong-kong-ipa-touts-low-taxes-market-access-to-phl-investors/
COA, BIR act on anomalous flood control projects
The Philippine Star / Daphne Galvez / August 27, 2025 MANILA, Philippines
The Commission on Audit (COA) has ordered the inspection of all flood control projects in Bulacan, particularly those with huge fund allocations, as it conducts a fraud audit covering over three years of public works spending. In a memorandum dated Aug. 20, COA Chairman Gamaliel Cordoba directed Technical Services Office director Flora Ruiz to “designate technical personnel for the immediate conduct of technical inspections of all ongoing and completed flood control projects” in Bulacan from Jan. 1, 2022 to July 30, 2025. The order instructed inspectors to prioritize projects based on contract cost, starting with the highest-valued projects.
Tax fraud audit – At the same time, the Bureau of Internal Revenue will conduct a tax fraud audit on contractors linked to anomalous flood control projects, following the administration’s order to investigate irregularities in government infrastructure spending. BIR Commissioner Romeo Lumagui Jr. said contractors found guilty of under-declaration or evading taxes will not be issued updated tax clearances, effectively disqualifying them from future government projects and suspending settlement of their current contracts. The BIR said the directive is anchored on its revenue regulation, which requires contractors to present an updated tax clearance before final payment of any government project. Hence, failure to do so will lead to the suspension of final settlement for the concerned government contract, along with the imposition of a tax lien over the contract amount in favor of the government,safeguarding public funds. Lumagui also addressed reports of “ghost” flood control projects, which the government had fully paid for and declared as completed, but which, upon subsequent verification and validation, were discovered to have never been actually constructed or physically undertaken.
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https://www.philstar.com/headlines/2025/08/27/2468318/coa-bir-act-anomalous-flood-control-projects
Corporate registrations surge after SEC expands one-day processing coverage
Manla Bulletin / James A. Loyola / August 27, 2025
The Securities and Exchange Commission (SEC) has expanded its list of industries that can avail of its one-day registration process as part of the Commission’s drive to make company registration faster and easier. The SEC said registrations have surged with the expansion of the list of industries eligible for the One-Day Submission and Electronic Registration of Companies (OneSEC) Zuper Easy Registration Online facility to 81 from 33. To encourage more micro, small, and medium enterprises (MSMEs) to register as corporations, the SEC has granted them a 20-percent discount in registration fees, and an up to 50-percent discount in the filing fee for those seeking to tap the capital market, with the issuance of Memorandum Circular (MC) No. 8, Series of 2025. In June, the SEC issued MC 6, Series of 2025, which reduced the rates for corporate data requests by half. The Commission has also imposed strict timelines in the processing of applications for permits, licenses, registrations, certificates, clearances, and other authorizations, through MC 7, Series of 2025. This also included the adoption of a “deemed approved” policy should the Commission fail to meet its own deadline for review.
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https://mb.com.ph/2025/08/27/corporate-registrations-surge-after-sec-expands-one-day-processing-coverage
Philippines could be hit with more tariffs as Trump threatens countries with digital taxes
Business World / Aubrey Rose A. Inosante and Justine Irish D. Tabile / August 27, 2025
THE PHILIPPINES may face additional tariffs after US President Donald J. Trump’s fresh tariff threat against countries that impose digital taxes on US technology companies, analysts said. In a post on Truth Social, Mr. Trump threatened countries that have digital taxes with “substantial additional tariffs” on their exports to the US if they do not remove these laws. “With this truth, I put all countries with digital taxes, legislation, rules, or regulations, on notice that unless these discriminatory actions are removed, I, as President of the United States, will impose substantial additional tariffs on that country’s exports to the USA, and institute export restrictions on our highly protected technology and chips,” Mr. Trump said. The Philippines, which began enforcing its digital tax law in June, may be among the countries facing additional US tariffs. Republic Act No. 12023 imposes a 12% VAT on nonresident digital service providers such as Netflix, Amazon, and Google. The law aims to level the playing field between local and foreign digital platforms.
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https://www.bworldonline.com/editors-picks/2025/08/27/693888/philippines-could-be-hit-with-more-tariffs-as-trump-threatens-countries-with-digital-taxes/
DTI: Philippines diversifying trade deals amid US tariff threats
Philstar.com / Jean Mangaluz / August 28, 2025 – MANILA, Philippines
The United States (US) is not the Philippines’ lone market, Department of Trade and Industry (DTI) Secretary Cristina Aldeguer-Roque said on Thursday, with trade deals with the United Arab Emirates (UAE) and the European Union (EU) possibly mitigating the effects of President Donald Trump’s tariffs. In a Senate hearing to determine the scope of the tariffs’ possible effects on the Philippines, the DTI acknowledged that the US is a big partner in terms of trade. It tops the list of Manila’s top trading partners. Trade with the US amounted to $20.3 billion, with the trade balance estimated at $4 billion in favor of the Philippines. The DTI said that as the US enacts policies to address trade deficits and strengthen local manufacturing, the Philippines will act to address the possible fallout from the tariffs.
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https://www.philstar.com/business/2025/08/28/2468747/dti-philippines-diversifying-trade-deals-amid-us-tariff-threats
BSP cuts policy rates by another 25 basis points
Philippine News Agency / Anna Leah Gonzales / August 28, 2025 – MANILA
The Bangko Sentral ng Pilipinas (BSP) on Thursday delivered another 25 basis points cut in interest rates. The latest cut brings the BSP’s reverse repurchase rate to 5 percent and the interest rates on the overnight deposit and lending facilities to 4.5 percent and 5.5 percent, respectively. The BSP has so far reduced policy rates by a total of 150 basis points since last year. “Based on the latest data, I think this puts us at our sweet spot for both inflation and output. The projected inflation rate over the next year or so is where we wanted to be. Output is moving to where we think our capacity is,” said BSP Governor Eli Remolona Jr. in a briefing at the BSP office in Manila. “The policy rate itself is at our Goldilocks rate, neither too high, not too low. I would characterize this as still dovish but slightly less so than before in terms of the forward guidance. We came to this decision after weighing many different scenarios,” he added. Remolona said the BSP sees the inflation outlook to be “very manageable.”
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https://www.pna.gov.ph/articles/1257522
SSS net income to exceed P100-B in 2025
Philippine News Agency / Anna Leah Gonzales / August 28, 2025 – MANILA
State-run Social Security System (SSS) is expecting its net income to exceed PHP100 billion this year. “So definitely, we’ll reach the PHP100 billion mark in net income for 2025. So we estimate that in terms of percentage growth of net income, it will range from about 38 to about 43 percent year-on-year,” SSS President and chief executive officer Robert Joseph de Claro said in a brieifng at the SSS office in Quezon City on Thursday. Last year, the net income of SSS reached PHP90.2 billion. De Claro said half of the projected net income for this year would come from the agency’s investments. For next year, SSS is projecting at least 8 percent further increase in its net income.
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https://www.pna.gov.ph/articles/1257492
BIR begins work on tax fraud audit of flood contractors
Business World / Aubrey Rose A. Inosante / August 28, 2025
THE Bureau of Internal Revenue (BIR) has started the paperwork in investigating contractors flagged for irregularities in flood control projects, including Discaya-linked contractors. “We’ve already issued the memorandum. We’ve conducted the initial steps like issuance of the letters of authority that will start the formal audit process,” Commissioner Romeo D. Lumagui, Jr. said in his interview with Money Talks with Cathy Yang on One News. The probe announced this week follows President Ferdinand R. Marcos, Jr.’s recent disclosure that 15 contractors cornered approximately P100 billion, or around 20% of the P545-billion flood control budget since 2022. Among those identified were Omega & Alpha Construction and St. Timothy Construction, both reportedly linked to former Pasig mayoral candidate Cezarah Rowena “Sarah” Discaya for alleged anomalous flood control projects.
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https://www.bworldonline.com/editors-picks/2025/08/28/694520/bir-begins-work-on-tax-fraud-audit-of-flood-contractors/
BSP cuts key rate to 5% amid favorable inflation outlook
Manila Bulletin / Derco Rosal / August 28, 2025
Citing steady domestic demand coupled with still-tame inflation, the Bangko Sentral ng Pilipinas (BSP) has delivered its widely expected third key policy rate cut, lowering it by a quarter of a point to five percent. “The Monetary Board (MB) observed that domestic demand has held firm,” BSP Governor Eli M. Remolona Jr. said in a statement released on Thursday, Aug. 28. “However, the impact of United States (US) policies on global trade and investment continues to weigh on global economic activity. This could temper the outlook for the Philippine economy,” Remolona said. To date, the policy-setting MB has slashed the key interest rate by a total of 1.5 percentage points (ppt) from 6.5 percent before the easing cycle began in August last year. For this year alone, the BSP has reduced the key interest rate by 75 bps across three consecutive policy meetings in April, June, and August
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https://mb.com.ph/2025/08/28/bsp-cuts-key-rate-to-5-amid-favorable-inflation-outlook
PEZA exceeds ₱100 billion in investment pledges on strong investor confidence
Manila Bulletin / Dexter Barro II / August 28, 2025
Investment pledges approved by the Philippine Economic Zone Authority (PEZA) have exceeded ₱100 billion in the first eight months of the year, fueled by strong investor confidence in the country. In a statement, the PEZA said it has approved investments worth ₱105.83 billion from January to August, a 72 percent increase from ₱61.69 billion during the same period last year. “Investors are voting with their capital, and they are choosing the Philippines as a place to grow their businesses,” said PEZA Director General Tereso Panga. These pledges, which will eventually materialize into actual investments, cover 179 new and expansion projects—up 9.82 percent from 163 projects in the previous year.
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https://mb.com.ph/2025/08/28/peza-exceeds-100-billion-in-investment-pledges-on-strong-investor-confidence
AstraZeneca wins P37M VAT refund from BIR
Bilyonaryo.com / August 29, 2025
The Court of Tax Appeals (CTA) Second Division has ordered the Bureau of Internal Revenue (BIR) to pay ₱37.15 million or issue a tax credit to AstraZeneca Pharmaceuticals Inc., ruling that the agency illegally collected value-added tax (VAT) on imported medicines already exempt under Philippine law. The case involved shipments of prescription drugs for diabetes, high cholesterol, and hypertension imported between January and April, and in August 2020. Under Republic Act 11467, VAT exemptions for certain medicines took effect on Jan. 1, 2020.
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https://bilyonaryo.com/2025/08/29/astrazeneca-wins-p37m-vat-refund-from-bir/health/
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