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The Bureau of Internal Revenue (BIR) has issued Revenue Regulations (RR) No. 19-2025 last August 5, 2025.  This regulation implements key provisions of Republic Act No. 12214, also known as the “Capital Markets Efficiency Promotion Act” (CMEPA). The regulation introduces significant adjustments to the Documentary Stamp Tax (DST) rates and expands exemptions for certain financial instruments. This covers documents made or accomplished on July 1, 2025 onwards.

Amended DST Rates on Key Transactions

Under RR No. 19-2025, the DST rate on the original issuance of shares of stock has been reduced to 75% of 1% of the par value, from the previous rate of P2 for every P200 par value and a fraction thereof. For shares without par value, the tax is based on the actual consideration, while stock dividends are taxed based on their actual value.

Similarly, the DST on bonds, debentures, and certificates of stock or indebtedness issued in foreign countries is now introduced at 75% of 1% of the transaction value. 

For all debt instruments, including loan agreements, promissory notes, and government securities, the DST is also set at 75% of 1% of the issue price. For instruments with terms less than one year, the tax is proportionally adjusted based on the number of days relative to a full year.  Furthermore, when multiple instruments secure a single loan, only one DST will be imposed, calculated on the instrument that yields the higher tax, and notably, the multiple instruments covered now includes not only loan agreements or promissory notes, but also mortgage, security interest over personal property, and other contracts.

Expanded DST Exemptions

RR No. 19-2025 also amends Section 199 of the Tax Code to broaden the list of documents and papers exempt from DST. These now include:

  • Sale, exchange, redemption, or other disposition of shares listed and traded through local or foreign stock exchanges.
  • Original issuance, redemption, or other disposition of shares in a mutual fund company.
  • Issuance of certificates or other evidence of participation in mutual funds or unit investment trust funds (UITFs).

Please be guided accordingly. 

 

Source:  

P&A Grant Thornton  

Certified Public Accountants  

P&A Grant Thornton is the Philippine member firm of Grant Thornton International Ltd.

 

As published in SunStar Cebu, dated 22 August 2025