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Tax Alert

Implementation of the Revised Documentary Stamp Tax Rates and Exemptions under CMEPA

(Revenue Regulations No. 19-2025 issued on August 5, 2025)

This Tax Alert is issued to inform all concerned of the implementation of the rate adjustments for DST under Sections 174, 176, and 179 of the National Internal Revenue Code (Tax Code) and the amendments on the documents and papers not subject to DST under Section 199 of the same Code pursuant to Republic Act (RA) No. 12214, otherwise known as the Capital Markets Efficiency Promotion Act (CMEPA). 

A. Definition of Terms 

a. Mutual Fund Company shall refer to an open-end and close-end company as defined under the Investment Company Act.

b. Unit Investment Trust Fund shall refer to 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.

c. Debt Instrument shall refer to instruments representing borrowing and lending transactions, including but not limited to the following:

  • Debentures;
  • Certificates of Indebtedness;
  • Due 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;
  • 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 having a specific maturity date; and
  • Promissory notes, whether negotiable or non-negotiable, except bank notes issued for circulation

B. Revised DST Rates

In line with the enactment of CMEPA, the following changes to DST rates have been implemented effective July 1, 2025.

C. Additional documents and papers not subject to DST 

The documents and papers not subject to stamp tax under CMEPA now include the following:

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

b. Original issuance, redemption, or other disposition of shares in a mutual fund company

c. Issuance of certificate or other evidence of participation in a mutual fund or unit investment trust fund

D. Transitory Period

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

These Regulations take effect on July 1, 2025, following its publication in the Official Gazette or the Bureau of Internal Revenue’s official website, whichever comes first.

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