RMC No. 61-2025 — Circularizing Section 27 of RA No. 12214, titled "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, Otherwise Known as the National Internal Revenue Code of 1997, as Amended, and for Other Purposes"

Bringing In Revenues for Nation-Building BUREAU OF INTERNALREVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE National Office Building Quezon City JUN 19 2025 PILIPINAS BAGONG

REVENUE MEMORANDUM CIRCULAR NO. 0 6_1 - 2 0.2 5

SUBJECT:Circularizing Section 27 of Republic Act No.12214,entitled 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 REPUBLICT ACT NO 8424, OTHERWISE KNOWN AS THE NATIONAL INTERNAL REVENUE CODE OF 1997, AS AMENDED, AND FOR OTHER PURPOSES"

TO: All Internal Revenue Officials, Employees and Others Concerned

For the information and guidance of all internal revenue officials, employees and others concerned, this is to circularize Section 27 of Republic Act No.12214,otherwise known as the Capital Markets Efficiency Promotion Act(CMEPA), which provides for the repeal or modifications of the tax exemptions of certain transactions under various laws, to wit:

are hereby repealed or modified accordingly: "SEC. 27. Repealing Clause. - The following laws or provisions of laws

(a) Section 9, insofar as the tax exemption on the issuance of bonds and

securities is concerned, of Presidential Decree No. 1648, otherwise known as "Reorganizing the National Development Company and Establishing a Revised Charter Therefor"

(b) Sections 6, 7, and 8, insofar as the tax exemptions on interest income,

capital gains and documentary stamp tax, and on the issuance of bonds are concerned,of Executive Order No.603, otherwise known as "Creating a RUCCAD RF INTERNAN REVENUS Light Rail Transit Authority, Vesting the Same with Authority to Construct

JNIT A JUN 19 2025 o (c) Section 14, insofar as tax exemptions on interest income, capital gains, and Therefor".2 and Operate the Light Rail Transit (LRT) Project and Providing Funds documentary stamp tax are concerned,of Republic Act No.7354,otherwise

S Powers, Functions and Responsibilities, Providing for Regulation of the known as "An Act Creating the Philippine Postal Corporation, Defining its

Industry and for Other Purposes Connected Therewith ":

2 Interest income shall be subject to Income Tax; Capital Gains shall be subject to Capital Gains Tax and Issuance of bonds and securities shall be subject to Documentary Stamp Tax

3 Interest income shall be subject to Income Tax and Capital Gains shall be subject to Capital Gains Tax. issuance of bonds shall be subject to Documentary Stamp Tax.

BIR National Office Bldg., Senator Miriam Defensor-Santiago Avenue,Diliman, Quezon City Trunkline: 8981-7000 ; 8929-7676 Websitewww.bir.gov.ph

(d) Section 12. insofar as the tax exemptions on interest income, capital gains

and documentary stamp tax, and on the issuance of bonds are concerned,

Duties, Providing Funds Therefor, and for Other Purposes ". of Republic Act No.4850,otherwise known as"An Act Creating the Laguna Lake Development Authority, Prescribing its Powers, Functions and

(e) Number 8, insofar as tax exemptions on interest income, capital gains, and

Otherwise known as "Creating the Nayong Pilipino Foundation" documentary stamp tax are concerned, of Presidential Decree No. 37

(f) Section 12, insofar as tax exemptions on interest income, capital gains, and

documentary stamp tax are concerned, of Presidential Decree No. 205.

of the Philippines, Defining its Powers, Functions, and Responsibilities otherwise known as "Creating and Establishing the Development Academy

and for Other Purposes"

(g) Article 204, insofar as tax exemption of the state insurance fund on capital gains is concerned, of Presidential Decree No. 442, otherwise known as the

"Labor Code of the Philippines" as amended

(h) Sections 10 and 11, insofar as the tax exemptions on interest income, capital

gains, and documentary stamp tax of subsidiaries of Philippine Aerospace Development Corporation and on the issuance of bonds are concerned, of

Decree No. 286, dated September 5, 1973, as Amended, Otherwise Known Presidential Decree No. 696, otherwise known as "Revising Presidential

and for Other Purposes". as"The Charter of The Philippine Aerospace Development Corporation

MINUNIT R JUN 19 2025 S RF INTERMANT (i) Section 2(g), insofar as the tax exemptions on interest income and on the Republic Act No. 2081, otherwise known as "An Act Creating the Rehabilitation Finance Corporation", issuance of bonds are concerned, of Republic Act No. 85, as amended by

I 43 R (i) Sections 76, 77, and 98, insofar as tax exemptions on interest income Otherwise known as the "Agricultural Land Reform Code " ro dividends, capital gains, and the documentary stamp tax on bonds are concerned, of Republic Act No. 3844, as amended by Republic Act No. 6389

(k) Section 24, insofar as the tax exemptions on interest income and on the issuance of bonds are concerned, of Republic Act No. 3591, as amended by Republic Act No. 9576 and Republic Act No. 10846, otherwise known as

10 Interest income and Dividends shall be subject to Income Tax and capital gains shall be subject to Capital 7 Capital Gains shall be subject to Capital Gains Tax. 8 Interest income shall be subject to Income Tax and Capital Gains shall be subject to Capital Gains Tax. Gains Tax. 6 Interest income shall be subject to Income Tax and Capital Gains shall be subject to Capital Gains Tax. 9 Interest income shall be subject to Income Tax and issuance of bonds shall be subject to Documentary Stamp 4 Interest income shall be subject to Income Tax; Capital Gains shall be subject to Capital Gains Tax and 5 Interest income shall be subject to Income Tax and Capital Gains shall be subject to Capital Gains Tax. issuance of bonds shall be subject to Documentary Stamp Tax Tax

as The PDIC Charter, and for Other Purposes". Connection Therewith, to Strengthen the Regulatory and Administrative Authority, and Financial Capability of the Philippine Deposit Insurance Three Thousand Five Hundred Ninety-One, as Amended, Otherwise Known Corporation (PDIC), Amending for this Purpose Republic Act Numbered "An Act Increasing the Maximum Deposit Insurance Coverage, and in

(l) Section 12, insofar as tax exemptions on interest income, capital gains, and Purposes".12 Retirement Park System, Providing Funds Therefor and for Other documentary stamp tax, and on the issuance of bonds are concerned, of Executive Order No. 1037,otherwise known as "Creating the Philippine

(m)xxx (vetoed by the President);

(n) Section 8(a), insofar as tax exemptions on interest income, capital gains, the Charter of the National Power Corporation" 13 Section 1 of Republic Act No.6395, otherwise known as "An Act Revising and documentary stamp tax of bonds are concerned, as provided under

(o) Sections 9 and 15, insofar as the tax exemptions on interest income, capital Other Purposes ":14 otherwise known as "Creating the Philippine National Oil Company, Defining its Powers and Functions, Providing Funds Therefore, and for gains, documentary stamp tax, and on the issuance of bonds are concerned. of Presidential Decree No.334,as amended by Presidential Decree No.572,

(p) Section 16, insofar as tax exemption on capital gains is concerned, of Premium Subsidy, and for Other Purposes "is Presidential Decree No. 1467, otherwise known as "Creating the Activities, Providing for its Capitalization and for the Required Government Philippine Crop Insurance Corporation, Prescribing its Powers and

(q) Section 56, insofar as tax exemption on capital gains is concerned, of Administration".1 Republic Act No. 10801, otherwise known as An Act Governing the Operations and Administration of the Overseas Workers Welfare

(r) Section 28, insofar as tax exemption on documentary stamp tax is concerned, of Republic Act No. 9267, otherwise known as the "Securitization Act of 2004"

14 Interest income shall be subject to Income Tax; capital gains shall be subject to Capital Gains Tax and issuance of bonds shall be subject to Documentary Stamp Tax. 16 Capital gains shall be subject to Capital Gains Tax. 12 Interest income shall be subject to Income Tax; capital gains shall be subject to Capital Gains Tax and issuance of bonds shall be subject to Documentary Stamp Tax 11 Interest income shall be subject to Income Tax and issuance of bonds shall be subject to Documentary Stamp 13 Interest income shall be subject to Income Tax and capital gains shall be subject to Capital Gains Tax 15 Capital gains shall be subject to Capital Gains Tax. Tax @RECEAY SFINTERNA MAGEMENT DIVISION AL REVENUE

JUN 19 2025

BY: ADMIN UNIT LIME 1:4

(s) Section 6 of Republic Act No. 6426, otherwise known as the "Foreign

Currency Deposit Act of the Philippines, as amended":

(t) Section 16(b), insofar as tax exemptions on interest income, dividends, and

Purposes"18 capital gains are concerned, of Republic Act No. 9497, otherwise known as Authorizing the Appropriation of Funds Therefor, and for Other "An Act Creating the Civil Aviation Authority of the Philippines.

JUN 19 2025 DUBA (u) Section 21, insofar as tax exemptions on interest income, dividends, and capital gains are concerned, of Republic Act No.7356, otherwise known as "An Act Creating the National Commission for Culture and the Arts, DMIN UNIT ME Other Purposes ".19 Establishing a National Endowment Fund for Culture and the Arts, and for

G C ERMENTREVESNUE (v) Section 23(a), insofar as tax exemptions on interest income, dividends; and as "An Act Strengthening Peoples Nationalism through Philippine History Powers and Functions, and for Other Purposes ".20 by Changing the Nomenclature of the National Historical Institute into the capital gains are concerned, of Republic Act No. 10086. otherwise known National Historical Commission of the Philippines, Strengthening its

(w) Section 11, insofar as tax exemptions on interest income, dividends, and

capital gains are concerned, of Presidential Decree No. 1201, series of

Development Studies ".2i 1977,otherwiseknown as "Creating the Philippine Institute for

(x) Section 11, insofar as tax exemptions on interest income, dividends, and capital gains are concerned, of Republic Act No. 2640, as amended by Batas Pambansa Bilang 35, otherwise known as "An Act to Create a Public

Defining its Powers, and for Other Purposes ".22 Corporation to be Known as the Veterans Federation of the Philippines.

(y) Section 12, insofar as tax exemptions on interest income, dividends, and capital gains are concerned, of Republic Act No.4156,as amended by Republic Act No.6366,otherwise known as "An Act Creating the Philippine

2 Interest income and dividends shall be subject to Income Tax and capital gains shall be subject to Capital Gains Tax. 22 Interest income and dividends shall be subject to Income Tax and capital gains shall be subject to Capital 17 Interest income on foreign currency deposits of residents shall be subject to Income Tax. 18 Interest income and dividends shall be subject to Income Tax and capital gains shall be subject to Capital 20 Interest income and dividends shall be subject to Income Tax and capital gains shall be subject to Capital Gains Tax. 19 Interest income and dividends shall be subject to Income Tax and capital gains shall be subject to Capital Gains Tax. Gains Tax. Gains Tax.

Providing for the Necessary Funds for its Operation",23 and National Railways, Prescribing its Powers, Functions and Duties, and

(z) Section 15, insofar as tax exemptions on capital gains and documentary stamp are concerned, of Republic Act No. 9182, as amended by Republic

Other Purposes " 24 Act No. 9343, otherwise known as 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

issuances, or any part thereof inconsistent with the provisions of this Act are deemed repealed, amended, or modified accordingly." All laws, decrees, executive orders, implementing rules and regulations

exemptions provided under the above enumerated provisions are no longer available and the Thus, beginning July 1,2025,which is the effectivity date of the CMEPA, the tax

without prejudice to the transitory provision under Section 28 of the CMEPA. corresponding transactions related thereto are already subject to applicable taxes. This is

All internal revenue officials and employees are hereby enjoined to give this Circular as wide a publicity as possible.

ROMEO D.LUMAGUI,JR mmissioner of Internal Revenue

K-1

AR RECOPDS MANAGEMENTDIVISION SCA OFINTERNALREVENUE

S

JUN 19 2025

3 ADMIN UNIT IM F3

23 Interest income and dividends shall be subject to Income Tax and capital gains shall be subject to Capital 24 Capital gains shall be subject to Capital Gains Tax. Gains Tax.