RR No. 19-2025 — Implementing the Documentary Stamp Tax (DST) Rate Adjustments and Amendments to the Documents and Papers Not Subject to DST Under Republic Act No. 12214, Otherwise Known as the "Capital Markets Efficiency Promotion Act" (Date Posted: August 5, 2025)

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Bringing In Revenues for Nation-Building National Office Building Que=on City PILIPINAS BAGONG AUIG 0 5 2025

REVENUE REGULATIONS NO. 019-2025

SUBJECT Implementing the Documentary Stamp Tax (DST) Rate Adjustments

and Amendments to the Documents and Papers Not Subject to DST Under Republic Act No. 12214, Otherwise Known as the "Capital Markets Efficiency Promotion Act"

TO All Internal Revenue Officials, Employees and Others Concerned

SECTION 1. SCOPE. Code of 1997, as amended (Tax Code), in relation to Sections 19, 20, 21, 23, and 25 of Republic Act (RA) No. 12214, otherwise known as the "Capital Markets Efficiency Promotion Act - Pursuant to Sections 244 and 245 of the National Internal Revenue

papers not subject to DST under Section 199 of the same Code. (CMEPA), these Regulations are hereby promulgated to implement the rate adjustments for DST under Sections 174, 176, and 179 of the Tax Code and the amendments to the documents and

property incident thereto in respect of the transactions made or accomplished on July 1, 2025 instruments, papers, acceptances, assignments, sales and transfers of the obligation, right or SECTION 2. COVERAGE. onwards. These Regulations shall cover documents, loan agreements,

SECTION 3. DEFINITION OF TERMS. -- For purposes of these Regulations, the following terms shall be taken to mean as follows:

(a) Mutual Fund Company -- an open-end and close-end company as defined under the Investment Company Act.

(b) Unit Investment Trust Fund -- an open-ended pooled trust fund denominated in peso or any acceptable currency, which is established, operated, and administered by a trust entity

and made available by participation.

4:23M ADMIN UNITME: 3 AUG 0 5 2025 TERMEN RENESNUE L e (c) Debt Instrument - shall mean instruments representing borrowing and lending certificates or other evidences of deposits that are either drawing interest significantly higher than the regular savings deposit taking into consideration the size of the deposit and the risks involved or drawing interest and having a specific maturity date, promissory notes, whether negotiable or non-negotiable, except bank notes issued for circulation. bills, bonds, loan agreements, including those signed abroad wherein the object of contract is located or used in the Philippines, instruments and securities issued by the government or any of its instrumentalities, deposit substitutes, debt instruments. transactions, including but not limited to debentures, certificates of indebtedness, due

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

SECTION 4. NEW RATE OF DST ON ORIGINAL ISSUE OF SHARES OF STOCK. Section 174 of the Tax Code, as amended by Section 19 of the CMEPA, now reads as follows:

original issue, whether on organization, reorganization or for any lawful purpose, of shares of stock by any association, company or corporation, there "SEC. 174. Stamp Tax on Original Issue of Shares of Stock. - On every

shall be collected a documentary stamp tax of SEVENTY-FIVE PERCENT

represented by each share. " (Emphasis supplied) OF ONE PERCENT (75% OF 1%) of the par value of such shares of stock: Provided, That in the case of the original issue of shares of stock without par value, the amount of the documentary stamp tax herein prescribed shall be Provided, further, That in the case of stock dividends, on the actual value based upon the actual consideration for the issuance of such shares of stock.

SECTION 5. NEW RATE OF DST ON BONDS, DEBENTURES, AND CERTIFICATES OF STOCK INDEBTEDNESS ISSUED IN FOREIGN COUNTRIES.- Section l76 of the Tax Code, as amended by Section 20 of the CMEPA, now reads as follows:

Indebtedness Issued in Foreign Countries. -- A documentary stamp tax of SEVENTY-FIVE PERCENT OF ONE PERCENT (75% OF 1%) of the "SEC 176. Stamp Tax on Bonds, Debentures, and Certificates of Stock or

value of the transaction shall be collected from the person selling or transferring bonds, debentures, certificates of stock, or certificates of indebtedness issued in any foreign country. " (Emphasis supplied)

SECTION 6. NEW RATE OF DST ON ALL DEBT INSTRUMENTS.-- Section 179 of the Tax Code, as amended by Section 21 of the CMEPA, now reads as follows:

debt instruments, there shall be collected a documentary stamp tax of issue price of any such debt instrument: Provided, That for such debt further, That only one documentary stamp tax shall be imposed on the loan agreement and promissory notes, mortgage, security interest over personal instruments with terms of less than one (1) year, the documentary stamp tax to be collected shall be of a proportional amount in accordance with the ratio of its term in number of days to three hundred sixty-five (365) days: Provided property, and other contracts issued to secure such loan." (Emphasis SEVENTY-FIVE PERCENT OF ONE PERCENT (75% OF 1%) of the "SEC. 179. Stamp Tax on All Debt Instruments. -- On every original issue of

supplied)

the instrument shall be treated as covering only one taxable transaction. mortgage, security interest over personal property and other contracts issued to secure such loan. whichever will yield a higher tax. Moreover, where only one instrument was prepared, made, signed or executed to cover a loan agreement/promissory note/pledge/mortgage, the DST executed, only one DST shall be imposed on either loan agreement or promissory note, Trust, shall be paid and computed on the full amount of the loan or credit granted. In this regard. personal property and other contracts issued to secure such loan are simultaneously issued and prescribed in Section 195 of the Tax Code, on Stamp Tax on Mortgages, Pledges and Deeds of In cases where a loan agreement and a promissory note, mortgage, security interest over

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SECTION 7.DOCUMENTS AND PAPERS NOT SUBJECT TO STAMP TAX. - Section 199 of the Tax Code, as amended by Section 23 of the CMEPA, now reads as follows:

"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:

XXX

(e) Sale, exchange, redemption, or other disposition of shares of stock listed and traded through a local or foreign stock

exchange

XXX

( Original issuance, redemption, or other disposition of

Shares in a mutual fund company.

(p) a mutual fund or unit investment trust fund. " (Emphasis supplied) Issuance of certificate or other evidence of participation in

SECTION 8. SEPARABILITY CLAUSE. - subsequently declared invalid or unconstitutional, the validity of the remaining provisions hereof - If any of the provisions of these Regulations is

shall remain in full force and effect.

SECTION 9. REPEALING CLAUSE.- - All other issuances and rules and regulations or

hereby repealed, amended or modified accordingly. parts thereof which are contrary to and inconsistent with the provisions of these Regulations are

SECTION 10. EFFECTIVITY. following its publication in the Official Gazette or the Bureau of Internal Revenue's official -- These Regulations shall take effect on July l, 2025.

website, whichever comes first.

Selretaryfof Finance RALPH G/RECTO JUV/29 2925

Recommending Approval:

missioner of Internal Revenue LUMAGUI, JR B RECORQS MANAGEMENTDIVISION BUREAU OF INTERNAL REVENUE

AUG 05 2025

ADMINUNIT. TMe: C:2M

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