Title
Supreme Court
Tax on Interest Income from Non-Securitized Loans
Law
Bir Revenue Memorandum Circular No. 84-2012
Decision Date
Dec 21, 2012
This circular clarifies that interest income from loans not securitized, assigned, or participated out, specifically for the Top Twenty Thousand Corporations, is subject to a two percent Creditable Withholding Tax, while revoking any inconsistent prior rulings.

Q&A (BIR REVENUE MEMORANDUM CIRCULAR NO. 84-2012)

The Circular clarifies the tax treatment of interest income earnings on loans that are not securitized, assigned, or participated out.

The CWT rate is two percent (2%).

No, the Circular specifically addresses interest income on loans that are not securitized, assigned, or participated out.

Interest income paid remains subject to Creditable Withholding Tax at the rate of two percent (2%).

Section 57(8) of the Tax Code, as amended, in relation to Section 2.57.2 (M) of Revenue Regulations No. 2-98, as amended.

The twenty percent (20%) Final Withholding Tax (FWT) and Creditable Withholding Tax (CWT) cover interest on debt securities.

Sections 24(B)(1), 25(A)(2), 27(D)(1), 28(A)(7)(a), and Section 57(B) of the Tax Code, as amended.

All prior issuances including rulings inconsistent with this Circular are revoked or modified accordingly.

The Circular took effect immediately upon its release.

All revenue officers and employees are enjoined to give the Circular as wide publicity as possible.


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