Title
Supreme Court
Tax Base for Real Property Sales
Law
Bir Revenue Audit Memorandum Order No. 2-91
Decision Date
Feb 18, 1991
BIR Revenue Audit Memorandum Order No. 2-91 updates the tax base determination for the sale, transfer, or disposition of real property and improvements, amending previous regulations to ensure accurate internal revenue tax assessments.

Law Summary

Definitions of Key Terms

  • Agricultural land: Land devoted to raising crops, pasturing, dairying, fishing, salt-making, including timber and forest lands (Real Property Tax Code, P.D. No. 464 as amended)
  • Commercial land: Land primarily used for commercial profit-making purposes, including its improvements (Real Property Tax Code)
  • Condominium: An interest in real property consisting of separate units with undivided interest in common areas and land (Condominium Act, R.A. No. 4726)
  • Condominium Unit: A designated part of a condominium project used independently, may include multiple rooms/floors and accessories (Condominium Act)
  • Improvement: Valuable addition or enhancement to property that improves its value, beauty, or utility beyond mere repairs (Real Property Tax Code)
  • Industrial land: Land principally devoted to industrial capital investment, including improvements (Real Property Tax Code)
  • Townhouse: An independent dwelling attached by party walls on adjacent lots (Housing and Planning Manual by De Chiara and Koppelman)

Determination of Tax Base: When Zonal Value is Established

  • Compute value of improvement either by:
    • Selling price less zonal value of land, or
    • Construction cost per permit plus 10% per year after construction, or
    • Market value per latest tax declaration plus 100%/150%
  • Tax base formula: Zonal value of land plus market value of improvement (whichever method yields higher value)

Determination of Tax Base: When Zonal Value is Not Established

  • Use either:
    • Total selling price per deed of sale, or
    • Market value of land plus improvements (construction cost plus 10% annual increase or market value plus 100%/150%)
  • Tax base is the higher of these values

Market Value of Land

  • Add 100% to market value per latest tax declaration generally
  • For commercial, industrial, agricultural devoted to fishpond or prawn farm, add 150%

Market Value of Improvement

  • For improvements constructed 1986 to 1990:
    • Use construction cost from building/occupancy permit plus 10% per year after construction
    • For places without permits outside NCR and chartered cities, use market value plus 100%
    • Add 150% for commercial, industrial, and agricultural fishpond/prawn farm
  • For improvements constructed 1985 and earlier:
    • Use market value per latest tax declaration plus 100%, or plus 150% for commercial, industrial, and agricultural fishpond/prawn farm

Additional Requirements on Transfer or Disposition

  • If property has no improvements, taxpayer must submit an affidavit or certification from local assessor confirming no existing improvements

Amendatory and Effectivity Provisions

  • This Order amends previous RMO 3-87, RAMO 1-88, and other inconsistent issuances
  • Effective immediately upon adoption on February 18, 1991

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.