Title
Tax rules on stock option plans
Law
Bir Revenue Memorandum Circular No. 79-2014
Decision Date
Oct 31, 2014
BIR Revenue Memorandum Circular No. 79-2014 clarifies the tax treatment of stock option plans, detailing the tax implications for grants, sales, transfers, and exercises of both equity-settlement and cash-settlement options, along with associated reportorial requirements.

Law Summary

Tax Treatment: Grant of Option

  • When granted by an employer to an employee with no payment, the employer cannot claim deductions for the grant.
  • If the option is granted for a price, the full price is treated as capital gains and taxed.
  • Documentary Stamp Tax applies upon issuance: ₱0.75 per ₱200, or fraction thereof, of the par value of the underlying stock, or 25% of tax paid on original issue if no par value.

Tax Treatment: Sale or Transfer of Option

  • Sale, barter, or exchange of stock options is treated as sale of unlisted shares.
  • Capital gains tax applies under Section 24(C) of the NIRC on transfers with consideration.
  • If granted or transferred without consideration, cost basis is zero.
  • Transfers without consideration are treated as donations subject to donor's tax, based on fair market value at donation.

Tax Treatment: Exercise of Option

  • Equity-settlement Options:
    • Grantee pays exercise price and receives shares.
    • For rank-and-file employees, difference between book/fair market value and exercise price is additional taxable compensation subject to income and withholding tax.
    • For supervisory/managerial employees, difference is fringe benefit subject to fringe benefit tax under Section 33 of NIRC.
    • For suppliers of goods/services, difference is additional consideration subject to withholding tax and other applicable taxes.
    • For non-employees/suppliers, difference is considered a donation subject to donor's tax.
  • Cash-settlement Options:
    • Market value at exercise compared to exercise price; favorable difference paid by grantor to option holder.
    • Same tax rules as above apply.

Reportorial Requirements: Grant of Option

  • Issuing corporation must file a sworn statement within 30 days of grant to the Revenue District Office containing:
    • Terms and conditions, grantee information (names, TINs, positions)
    • Book value, fair market value, par value at grant date
    • Exercise price, exercise date or period
    • Taxes paid and amount paid for grant (if any)

Reportorial Requirements: Exercise of Option

  • During exercise period, issuer must submit report by 10th day succeeding the exercise month including:
    • Exercise date, grantee details (names, TINs, positions)
    • Book value, fair market value, par value at exercise date
    • Mode of settlement (cash or equity)
    • Taxes withheld and fringe benefits tax paid, if applicable

General Applicability

  • The tax treatments and reporting rules apply not only to stock options but also to other types of options.
  • Revenue officials are directed to disseminate these guidelines widely for proper compliance.

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