Title
Supreme Court
Adoption of VAT; amendments to tax code
Law
Executive Order No. 273
Decision Date
Jul 25, 1987
Corazon C. Aquino's Executive Order No. 273 establishes a multi-stage value-added tax (VAT) system to replace previous sales and percentage taxes, aiming to simplify tax administration and enhance equity in the taxation of goods and services.

Law Summary

Persons Subject to VAT

  • Applicable to persons in trade/business selling goods, rendering services, or importing goods.

VAT on Sale of Goods

  • 10% tax on gross selling price or gross value.
  • Zero-percent rate on export sales and sales exempted by special laws or international agreements.
  • Transactions deemed sales include transfers for non-business use, distribution to shareholders/creditors, consignments un-sold after 60 days, and business cessation inventories.
  • Tax calculations depend on invoicing method (separate billing or inclusive).
  • Sales returns, allowances, and discounts are deductible.
  • Commissioner of Internal Revenue (CIR) may determine appropriate tax base in special cases.

VAT on Importation of Goods

  • 10% VAT on total customs value plus duties and excise taxes, payable before release from customs.
  • Purchasers of tax-exempt imports who sell/transfer to non-exempt persons are deemed importers liable for VAT.

VAT on Sale of Services

  • 10% VAT on gross receipts from sale of services.
  • Zero percent rate applies to services paid by foreign currency for export-related activities and sales exempted by law or agreements.
  • Gross receipts include contract price, compensation, fees, and deposits excluding VAT.
  • Tax computed based on invoicing method as for goods.

Exempt Transactions from VAT

  • Sale of primary products (non-food agricultural, marine, forest) in original state by producers.
  • Importation or sale of basic agricultural/marine food products, fertilizers, petroleum (except specific items), books, vessels, personal effects under conditions, professional and educational services, and specified exempted service providers.
  • Services subject to percentage tax and sales/services by persons whose gross sales/receipts do not exceed prescribed thresholds.

Input Tax Credit and Excess Tax

  • Input tax credit allowed for VAT paid on goods/services used in business.
  • Excess input tax over output tax can be carried over or refunded under certain conditions.

Transitional Provisions on Input Tax Credit

  • Persons newly VAT liable or registered may claim input tax credit on beginning inventory at 8% value or actual VAT paid.

Refunds and Tax Credits for Input Tax

  • Exporters and persons with zero-rated sales may apply for tax credit certificates or refunds within 2 years with required documentation.
  • Refunds for input tax on capital goods may be applied after specified periods.
  • Refunds processed within 60 days on valid application.

Registration of VAT Taxpayers

  • VAT-liable persons must register with the appropriate Revenue District Officer.
  • Threshold for compulsory registration prescribed by Secretary of Finance.
  • Optional registration for exempt persons.
  • Cancellation of registration upon cessation of VAT liability.

Invoicing and Accounting by VAT Registered Persons

  • VAT registration number must appear on invoices/receipts.
  • Details of tax billing (separate or inclusive) indicated.
  • Maintenance of subsidiary sales and purchase journals required.

Notification Obligations

  • Changes in principal place of business or branches must be reported within 15 days.
  • Changes or termination of VAT status must be notified.

Filing of VAT Returns and Payment

  • Quarterly VAT returns filed and taxes paid at designated banks or offices.
  • Returns due within 20 days after quarter ends.
  • Initial taxable period may be prescribed by the Commissioner.

Power to Suspend Business Operations

  • Commissioner empowered to suspend businesses for failure to issue receipts, file returns, understate sales by 30% or more, or failure to register.
  • Suspension period minimum 5 days until compliance.

Imposition of Percentage Tax on Exempt Non-VAT Persons

  • Persons exempt from VAT who are not VAT registered pay 2% tax on gross quarterly sales.

Agents and Deputies for Tax Collection

  • Customs officers, heads of government offices, and accredited banks act as agents for collecting national internal revenue taxes.
  • Bank employees collecting taxes are subject to tax sanctions.

Authority of Commissioner to Assess and Enforce Taxes

  • Post-filing examination and assessment of tax returns.
  • Authority to estimate tax on failure to file or false returns using best evidence.
  • Power to conduct inventory, surveillance, and prescribe minimum gross sales.
  • Power to terminate taxable periods in cases of tax evasion or obstruction.
  • Authority to determine real property values for tax.
  • Can inquire into bank deposits for tax purposes.
  • Authority to accredit and register tax agents.
  • Can prescribe procedural requirements for tax administration.

Excise Taxes on Goods

  • Excise taxes imposed on manufactured, produced, or imported goods, in addition to VAT.
  • Taxes classified as specific (per unit) or ad valorem (percentage of price).

Special Excise Tax Provisions

  • Payment responsibilities and schedules outlined for domestic products.
  • Specific rates prescribed for distilled spirits, wines, fermented liquors, cigars, cigarettes, manufactured oils, saccharine, automobiles, non-essential goods (jewelry, perfumes, yachts), mineral products.

Mineral Products

  • Excise taxes on coal, non-metallic minerals, metallic minerals, and indigenous petroleum.
  • Tax bases defined including market value and actual output.
  • Payment and filing procedures detailed, including bond filing options.

Registration and Issuance of Receipts

  • Business registration required prior to commencement.
  • Issuance of receipts/invoices for sales or services with prescribed details.
  • Records must be preserved for 3 years.

Repeal and Renumbering of Provisions

  • Repeals obsolete sections.
  • Renumbering of sections for clarity and organization.
  • Reorganization of tax law titles and chapters.

Transitory and Implementation Provisions

  • Transitional input tax credits allowed for VAT-registered persons from deferred sales tax credits and inventory valuations.
  • Replacement of old tax credit certificates.
  • Mandatory registration for persons exceeding sales threshholds by specified date.
  • Funding for implementation from existing appropriations.
  • Secretary of Finance empowered to promulgate implementing rules.
  • Commissioner to consolidate internal revenue laws.
  • Inconsistent laws, rules, and regulations repealed or amended.
  • Effective date set for January 1, 1988, with immediate effect for registration provisions.

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