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A common issue for corporations holding proprietary club shares through officer-nominees is establishing that transfers such shares are not subject to Capital Gains Tax (CGT), Documentary Stamp Tax (DST), or Donor's Tax. Since proprietary club memberships are typically required to be registered in the name of a natural person, corporations often designate officers as nominees or trustees.
One of the most overlooked assets on a company's balance sheet is an unutilized Value Added Tax (VAT) input balance. For export-oriented businesses and other taxpayers entitled to VAT refunds, these amounts can represent significant cash recovery opportunities.
The Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 71-2026, clarifying the extended validity of Certificates of Compliance (COC) for cooperatives applying for a Certificate of Tax Exemption (CTE) in line with the extension granted by the Cooperative Development Authority (CDA) under Memorandum Circular No. 2026-07, Series of 2026.
The BIR’s move toward digital taxation is not merely changing how transactions are reported. It is placing greater visibility on how both businesses and regulators capture, process, and manage information.
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