Title
Supreme Court
Estate and Donor Tax Regulations under RA 7499
Law
Kri Revenue Regulation No. 17-93
Decision Date
Aug 30, 1993
KRI Revenue Regulation No. 17-93 implements Republic Act No. 7499, restructuring estate and donor's taxes by establishing new tax brackets and deductions for the transmission of a decedent's estate and donations, applicable to both residents and non-residents.

Law Summary

Estate Tax Rates

  • Estate tax applies to the net estate of every decedent, resident or non-resident:
    • Net estate up to P200,000: Exempt
    • P200,000 to P500,000: 5%
    • P500,000 to P2,000,000: 8% plus P15,000
    • P2,000,000 to P5,000,000: 12% plus P135,000
    • P5,000,000 to P10,000,000: 21% plus P495,000
    • Over P10,000,000: 35% plus P1,545,000

Governing Law for Estate Tax

  • Estate tax governed by the law in effect at decedent's death.
  • Succession and right to tax arise at death.
  • RA 7499 effective July 28, 1992, applies to deaths thereafter.

Computation of Net Estate and Deductions

  • Net estate calculated by deducting from gross estate:
    1. Expenses, losses, indebtedness, and taxes:
    • Funeral expenses (actual or 5% of gross estate, max P100,000), including medical expenses, mourning apparel, wake expenses, death notices, burial plot cost (only for plot where buried), and other interment rites.
    • Judicial expenses for estate proceedings.
    • Claims against the estate with requirements for notarization and statements for loans within three years.
    • Claims of deceased against insolvent persons included in gross estate.
    • Unpaid mortgages or indebtedness on included property.
    • Losses from casualty or theft not compensated and not previously claimed for income tax.
    1. Property previously taxed in prior estates or gifts within five years, with declining deduction rates over the years.
    2. Transfers for public use to government entities.
    3. The Family Home:
    • Deductible up to P1,000,000 at the higher of fair market or zonal value.
    • Must be certified by Barangay Captain.
    1. Net share of surviving spouse in conjugal partnership or community property.

Definitions

  • Family Home: Dwelling and land where family resides, must be certified by Barangay Captain.
  • Husband and Wife: Legally married man and woman.
  • Unmarried Head of Family: Unmarried person supporting dependents residing in family home.
  • Absolute Community of Property: Full merger of spouses' properties unless excepted.
  • Conjugal Partnership of Gains: Property regime agreed upon in marriage settlements involving separate and common property management.
  • Exclusive Property: Property owned by one spouse prior to marriage or acquired during marriage by certain titles.
  • Marriage Settlement: Contract fixing property relations before marriage.

Family Home Deduction Computation

  • Family home appraised at date of death at higher of current/fair market value or zonal value.
  • Deduction capped at P1,000,000.
  • Must be actual family residence at death, certified.
  • Different scenarios for unmarried heads, married with surviving spouse, conjugal or exclusive property, and situations with simultaneous spousal deaths.

Filing and Payment of Estate Tax

  • Estate tax return filed within six months of death.
  • Filed with Revenue District Officer or authorized official where decedent was domiciled.
  • Payment due upon filing of return.

Donor's Tax Rates

  • Annual total net gifts taxed progressively:
    • Up to P50,000: Exempt
    • P50,000 to P100,000: 1.5%
    • P100,000 to P200,000: 3%
    • P200,000 to P500,000: 5%
    • P500,000 to P1,000,000: 8%
    • P1,000,000 to P3,000,000: 10%
    • P3,000,000 to P5,000,000: 15%
    • Over P5,000,000: 20%
  • If donee is a stranger, a flat 10% rate applies.
  • Contributions to candidates and political parties governed by the Election Code.

Governing Law for Donor's Tax

  • Donor's tax applies on completed gifts (accepted and delivered).
  • Law in effect at completion governs taxation.
  • RA 7499 effective July 28, 1992 sets current rates.

Computation for Donor's Tax on 1992 Donations

  • Donations before July 28, 1992 taxed at old rates.
  • Donations on or after July 28, 1992 taxed at new rates.
  • Aggregation of donations within calendar year for tax computation.

Filing and Payment of Donor's Tax

  • Return filed within 30 days from gift date.
  • Filed at donor's domicile revenue office.
  • Payment due upon filing return.

Penalties for Non-compliance

  • Civil penalties and interest as per Sections 248 and 249 of the Tax Code.
  • Possible fines or imprisonment upon conviction according to Sections 253 and 254.

Repealing Clause

  • Previous inconsistent rules or orders are repealed or amended.

Effectivity

  • Regulations effective 15 days after publication.
  • Apply to property transfers by death or donation on or after July 28, 1992.

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