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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”

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Summary

RR No. 19-2025 implements the Documentary Stamp Tax (DST) rate adjustments and the amended list of documents not subject to DST under RA No. 12214 (CMEPA).

Key points

  1. Coverage. The Regulations cover documents, loan agreements, instruments, papers, acceptances, assignments, sales and transfers made or accomplished on July 1, 2025 onwards.
  2. Shares, foreign bonds and debt instruments. Under Sections 174, 176 and 179 of the Tax Code, DST is 75% of 1% of the par value of shares on original issue, 75% of 1% of the value of transactions for bonds, debentures and certificates issued in foreign countries, and 75% of 1% of issue price for debt instruments. Shares without par value use the actual consideration, and stock dividends use the actual value per share.
  3. Short-term debt instruments. For terms of less than one (1) year, the DST is proportional to the ratio of the term in days to 365 days.
  4. Loan agreements and security. Only one DST applies to a loan agreement and its promissory notes, mortgage, security interest over personal property and other securing contracts. If these are issued together, the DST is imposed on either the loan agreement or the other documents, whichever yields a higher tax. A single instrument covering a loan and security pays under Section 195 on the full loan or credit amount.
  5. Documents not subject to DST. Section 199 now exempts sale, exchange, redemption or other disposition of shares listed and traded through a local or foreign stock exchange, original issuance, redemption or disposition of shares in a mutual fund company, and certificates of participation in a mutual fund or unit investment trust fund.

Who is affected

  • Issuers of shares, bonds and debt instruments
  • Parties to loan agreements and their security documents
  • Mutual fund companies and unit investment trust funds

Deadlines and effectivity

  • Applies to transactions made or accomplished on July 1, 2025 onwards

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.