Tax Resources PH icon

TAX RESOURCES PH

Tax resources for Filipinos

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”

Files
Download this file

Summary

RMC No. 61-2025 circularizes Section 27 of RA No. 12214 (CMEPA), the repealing clause that repeals or modifies tax exemptions of certain transactions under various laws.

Key points

  1. What Section 27 repeals or modifies. It lists provisions in laws and decrees, items (a) to (z), insofar as they grant tax exemptions on interest income, dividends, capital gains, documentary stamp tax or the issuance of bonds. Examples include PD No. 1648, EO No. 603, RA No. 7354, RA No. 4850, RA No. 3591 (PDIC Charter), RA No. 6395 (NPC Charter) and RA No. 9182. Item (m) was vetoed by the President.
  2. Inconsistent issuances. All laws, decrees, executive orders, implementing rules, regulations and issuances, or parts of them, that are inconsistent with the Act are deemed repealed, amended or modified.
  3. Effect from July 1, 2025. Beginning July 1, 2025, the effectivity date of CMEPA, the exemptions under the listed provisions are no longer available. The related transactions are subject to applicable taxes, without prejudice to the transitory provision under Section 28 of the CMEPA.

Who is affected

  • Entities and transactions previously exempt under the listed laws and decrees

Deadlines and effectivity

  • Exemptions unavailable beginning July 1, 2025

Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.

Copies of BIR issuances are hosted here for reference. For the official version, check bir.gov.ph. Summaries by Tax Resources PH are not a substitute for the full text or professional advice.