Title
CREATE Act: Corporate Tax Reform 2021
Law
Republic Act No. 11534
Decision Date
Mar 26, 2021
The Corporate Recovery and Tax Incentives for Enterprises Act (CREATE) amends existing laws and executive orders in the Philippines, transferring the power of reviewing fiscal incentives to the Fiscal Incentives Review Board and making changes to various provisions to align with the new Act.

Law Summary

Transparency and Reporting Requirements

  • The Commissioner of Internal Revenue shall submit pertinent tax-related information on entities receiving incentives to the Secretary of Finance, subject to confidentiality provisions.
  • Submit biannual reports to Congressional Oversight Committee regarding tax incentive administration.

Expanded Definition of Corporation

  • Includes one-person corporations, partnerships, joint-stock companies, associations, excluding general professional partnerships and certain joint ventures related to specific industries.

Taxation on Nonresident Alien Individuals

  • Tax rate of 20% on dividends, interests, royalties, and winnings with specified exceptions and lower rate for royalties on books and music.
  • Exemptions on interest from certain long-term deposits subject to pre-termination penalties.

Corporate Income Tax Rates

  • General corporate income tax rate set at 25% effective July 1, 2020.
  • Reduced 20% rate for corporations with net taxable income ≤ P5 million and total assets ≤ P100 million.
  • Proprietary nonprofit educational institutions and hospitals taxed at 10%, reduced to 1% until June 30, 2023, with conditions.
  • Government-owned or controlled corporations taxed similarly to corporations in similar industries, with specified exceptions.
  • Intercorporate dividends generally exempt; foreign-sourced dividends exempt if reinvested under conditions.
  • Imposition of Minimum Corporate Income Tax (MCIT) of 2%, with a 1% reduced rate until June 30, 2023.

Taxation on Foreign Corporations

  • Foreign corporations engaged in business in the Philippines taxed at 25%, and minimum corporate income tax applies.
  • Specific provisions for regional or area headquarters and regional operating headquarters of multinational companies.
  • Final tax rates on interest, royalties, capital gains on non-listed shares, and intercorporate dividends.
  • Nonresident foreign corporations taxed on gross income at 25% with certain final withholding taxes.

Repeal of Improperly Accumulated Earnings Tax

  • Section imposing this tax repealed.

Allowable Deductions from Gross Income

  • Ordinary and necessary business expenses allowed; certain additional deductions for labor training within limits.
  • Allowable deductions include interest, taxes, losses, bad debts, depreciation, depletion, charitable contributions, research and development expenses.
  • Optional Standard Deduction (OSD) maintained.

Tax-Free Exchange of Property

  • No gain or loss recognized on reorganizations involving exchanges solely for stocks or securities under specified circumstances.
  • Conditions defined for control and permissible transactions.
  • Exemption from value-added tax on certain sales or exchanges.

Withholding Tax Review

  • Department of Finance to review withholding tax regulations every three years, with adjustments to rules as needed.

Value-Added Tax (VAT) Exemptions

  • Exemption from VAT on sales of low-cost to mid-priced residential properties, educational materials, specific prescription drugs and medicines, and certain COVID-19 related equipment and drugs.
  • Threshold sales amount exemptions related to gross annual sales.

Gross Receipts Tax for Non-VAT Persons

  • Tax set at 3% of gross quarterly sales or receipts for persons exempt from VAT, with cooperatives exempted.
  • Transitional reduced rate of 1% until June 30, 2023.

Authority of the Commissioner on Tax Refunds and Compromises

  • Refund claims require filing within two years after payment.
  • Commissioner to grant refunds within 90 days or provide written denial with legal basis.
  • Right of appeal to the Court of Tax Appeals.

Congressional Oversight Committee

  • Composition: Chairs of Senate and House Ways and Means Committees plus designated members.
  • Functions include legislative aid and oversight of the Fiscal Incentives Review Board.

Creation of New Title XIII - Tax Incentives

  • Scope covers all Investment Promotion Agencies (IPAs) unless exempt.
  • IPAs retain special law functions; DOF, BIR, and BOC retain mandates.
  • Tax incentives granted only to registered projects under approved Strategic Investment Priority Plan.

Definitions Related to Tax Incentives

  • Capital equipment, direct local employment, domestic input, export and domestic market enterprises, freeport zones, investment capital, and other relevant terms clearly defined.
  • Registered business enterprises exclude certain services like consultancy, financial services, retail, and restaurants.

Tax and Duty Incentives Offered

  • Types include Income Tax Holiday (ITH); Special Corporate Income Tax (SCIT) of 5% for qualifying enterprises; Enhanced Deductions (ED) on capital expenditure, labor, R&D, training, domestic input, power, reinvestment allowance, and net operating loss carry-over.
  • Duty exemption on importation of capital equipment and raw materials.
  • VAT exemption on importation and zero-rating on local purchases.
  • Specific conditions apply for each incentive type.

Conditions for Incentives Availment

  • ITH followed by SCIT or ED; cannot obtain SCIT and ED simultaneously.
  • Stricter conditions on labor, domestic input, and power expense deductions.
  • Duty exemptions conditional on exclusivity, local production status, usage, and prior approval.
  • Prohibitions and liabilities on unauthorized disposition within five years.
  • COVID-19 vaccine importations exempt from duties and taxes.
  • Petroleum product importers not entitled to incentives, paying applicable duties and taxes instead.

Period of Incentive Availment

  • Export and critical domestic market enterprises: ITH of 4-7 years plus 10 years of SCIT or ED.
  • Non-critical domestic market enterprises: ITH 4-7 years plus 5 years SCIT or ED.
  • Additional years for projects in conflict or disaster areas or relocating from NCR.
  • Location and industry tier classifications determine periods; tiers reviewed every three years.

The Fiscal Incentives Review Board (FIRB) - Powers and Functions

  • Policy-making and oversight on incentives granted by IPAs and other agencies.
  • Sets target performance metrics and reviews compliance.
  • Conducts monitoring, evaluation, audits, and cost-benefit analyses.
  • Approves/disapproves incentives and tax subsidies; hears appeals from adverse decisions.
  • Publishes firm-level incentive data and maintains masterlist of incentive-entitled products/services.

FIRB Composition and Support Structure

  • Chair: Secretary of Finance; Co-Chair: Secretary of Trade and Industry; Members include Executive Secretary, Budget Secretary, and NEDA Director General.
  • Technical committee with representatives from various government agencies.
  • Secretariat managed by National Tax Research Center.
  • Creation of specialized groups for fiscal incentives management, monitoring, evaluation, and legal matters.

Strategic Investment Priority Plan (SIPP)

  • Formulated by Board of Investments with input from FIRB, IPAs, government agencies, and private sector.
  • Valid for three years; focuses on investment, employment, exports, technology, innovation, environmental sustainability, supply chain enhancement, and market competitiveness.
  • Includes priority sectors, location tiers, and terms for enhanced deductions.
  • Projects must be listed in SIPP for incentive eligibility.

Presidential Powers

  • President may modify incentive mix, period, and manner for highly desirable projects upon FIRB recommendation.
  • Conditions include comprehensive sustainable development plan and minimum investment of P50 billion or employment of 10,000 workers.
  • Powers suspended during fiscal deficit emergencies.
  • May exempt IPAs or modify threshold requirements upon justified request.

Amendments and Publication

  • BOI may update SIPP including additions, suspensions, or alterations subject to criteria and publication.

Qualifications For Registered Enterprises

  • Must be engaged in SIPP-listed project.
  • Meet performance metrics.
  • Maintain adequate accounting and comply with electronic filing requirements.
  • Submit annual beneficial ownership reports.

Tax Incentives Management and Reporting

  • Registered enterprises must file tax returns electronically and submit annual tax incentives and benefits reports to IPAs and FIRB.
  • IPAs to submit consolidated reports to BIR.
  • BIR and BOC to provide actual tax and duty incentives data to DOF and maintain single database.
  • FIRB to publish cost-benefit analyses and submit annual reports to President and Congress.

Evaluation and Monitoring

  • FIRB mandated to conduct impact evaluations including cost-benefit analysis.
  • Third-party peer reviews allowed subject to data sharing agreements.

Penalties for Noncompliance

  • Graduated fines: P100,000 (1st violation), P500,000 (2nd), and cancellation of registration (3rd).
  • Registrations may be cancelled or incentives suspended for material misrepresentations or violations.
  • FIRB may order business closure for violations of excise and offenses provisions.
  • Government officials failing to provide data may face fines, suspension, or criminal/administrative penalties.

Transitory and Miscellaneous Provisions

  • Registered projects in economic zones/freeports must operate within geographical boundaries.
  • IPAs must establish one-stop centers for project facilitation.
  • Enterprises granted incentives before the Act remain eligible under specified conditions.

Repealing and Amendatory Clauses

  • Repealed various inconsistent laws and provisions regarding tax incentives and IPA powers.
  • Expanded FIRB's powers and membership, harmonizing overlapping laws.

Separability and Appropriation

  • If any provision is invalid, rest of Act remains effective.
  • P100 million initial appropriation for National Tax Research Center supporting FIRB.

Implementing Rules and Regulations

  • DOF Secretary to promulgate rules within 90 days; joint promulgation with DTI for Title XIII provisions.
  • Non-promulgation will not prevent Act's implementation.

Effectivity

  • Act effective 15 days after full publication.

This comprehensive reform establishes a more equitable, transparent, and performance-based corporate income tax and incentives system intended to p

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