Title
Investment Incentives Act - Investment Promotion Law
Law
Republic Act No. 5186
Decision Date
Sep 16, 1967
The Investment Incentives Act aims to attract Filipino and foreign investments in agricultural, mining, and manufacturing industries in the Philippines by providing incentives and protections to registered enterprises, including tax exemptions and the right to repatriate investment proceeds.

Law Summary

Declaration of Policy

  • Accelerate national economic development.
  • Promote economic nationalism.
  • Encourage dispersal of industries.
  • Support Filipino and foreign investments in agriculture, mining, and manufacturing.
  • Increase national income, exports, employment.
  • Raise living standards and equitable wealth distribution.
  • Encourage capital-intensive pioneer enterprises with joint Filipino and foreign capital.

Definition of Terms

  • "Board": Board of Investments.
  • "Registered enterprise": Corporation with at least 60% Filipino ownership and control involved in preferred investments, excluding banks and financial intermediaries.
  • "Technological assistance contracts": Transfer of patents, processes, or foreign technical/management assistance.
  • "Foreign loan": Financial assistance obtained from outside the Philippines registered with authorities.
  • "Foreign investments": Equity owned by non-Filipinos registered with authorities.
  • "Philippine National": Filipino citizens or corporations with 60% Filipino ownership and control.
  • "Preferred areas of investment": Economic activities designated by the Board.
  • "Pioneer enterprise": Enterprises producing goods not yet commercially made locally or using new production methods, processing local raw materials.
  • "Measured capacity": Board-determined desirable additional production volume without fostering monopolies.
  • "Tax credit": Tax credits given to registered enterprises, non-transferable, usable against taxes.
  • "Investment Priorities Plan": Plan prepared by the Board detailing demand, capacities, investment needs, raw materials, manpower, locations, government roles, tariffs, competition, etc.

Basic Rights and Guarantees

  • Repatriation of investment proceeds and earnings in original currency at prevailing exchange rates.
  • Remittance of sums for foreign loan obligations.
  • Protection from expropriation except for public use with just compensation.
  • Protection from requisition during war or emergency with compensation.

Incentives to Investors in Registered Enterprises

  • Protection of patents and proprietary rights.
  • Capital gains tax exemption if gains reinvested in registered enterprise stock within six months and held for five years.

Incentives to Philippine Nationals Investing in Pioneer Enterprises

  • Investment allowance deductible from taxable income up to 10%.
  • Capital gains tax exemption on reinvested proceeds with holding requirements.
  • Income tax exemption on gains from the sale of stock dividends within seven years.

Incentives to Registered Enterprises

  • Deduction for organizational and pre-operating expenses amortized up to ten years.
  • Accelerated depreciation options for fixed assets.
  • Net operating loss carry-over for six years.
  • Tax exemption on import duties for capital equipment if conditions met.
  • Tax credit for purchase of domestic capital equipment.
  • Tax credit for withholding tax on foreign loan interest under conditions.
  • Permission to employ foreign nationals in supervisory/technical/advisory positions up to five years.
  • Deduction on reinvestment of undistributed profits for approved capital expenditures.
  • Anti-dumping measures to protect from unfair import competition.
  • Protection from government agencies competing or importing tax-free.

Incentives to Pioneer Enterprises

  • Graduated tax exemptions on income taxes for up to 14 years.
  • Conditions on employing foreign nationals including registration and duration limitations.
  • Post-operative tariff protection up to 50% of dutiable value upon operation at commercial scale.

Special Export Incentives

  • Double deduction of promotional expenses abroad.
  • Double deduction of shipping costs with specific conditions.
  • Tax credit for raw materials used in exports.
  • Application approvals require proof of market creation and compliance with standards.

Preference in Grant of Government Loans

  • Government financial institutions prioritize financing registered and pioneer enterprises.
  • Participation restricted to Philippine Nationals.
  • Limited capital contribution by financial institutions (up to 30%).
  • Coordination among government financial institutions and reporting to the Board.

Private Financial Assistance

  • Insurance companies authorized to invest in stocks of registered enterprises under diversification rules.

Loans for Investment

  • Government insurance systems to provide five-year loans to members for buying shares in registered enterprises with escrow and amortization requirements.
  • Overall investment by these institutions capped at 49% of enterprise capitalization.

Board of Investments

  • Composition of five full-time members appointed by the President with confirmed qualifications and sector nominations.
  • Terms and appointment rules with administrative supervision under the Office of the President.

Qualifications and Compensation of Board Members

  • Qualifications: Filipino citizens, at least 30 years old, good character, professional competence.
  • Restrictions on political candidacy and financial interests during and after term.
  • Chairman and members receive fixed salaries and allowances.

Powers and Duties of the Board

  • Annual Investment Priorities Plan preparation.
  • Rulemaking and regulations.
  • Registration processing and certification.
  • Dispute resolution between investors and government agencies.
  • Recommendations on foreign nationals' employment.
  • Monitoring compliance and enforcement including cancellation of registration.
  • Staffing and management functions.
  • Conduct feasibility studies for pioneer areas.
  • Annual reporting to President and Congress.

Powers and Duties of the Chairman

  • Manage Board affairs and meetings.
  • Collect and provide statistical data.
  • Facilitate investor assistance and serve as liaison.

Preferred and Pioneer Areas of Investment

  • Annual submission of Investment Priorities Plan.
  • Criteria include economic gaps, market potential, employment, investment size, risk, indigenous resource use, profitability, competition.
  • Priority to high-return projects.
  • Inclusion of export-oriented activities meeting defined thresholds.
  • Procedures for approval and publication.
  • Amendment and appeals process with protections for vested rights.

Qualification of Applicants

  • Filipino ownership requirements or specific conditions for non-Filipino involvement in pioneer projects.
  • Obligation to become majority Filipino ownership within a prescribed period.
  • Capability and soundness assessments.
  • Accounting requirements to separate preferred projects.
  • Relaxed ownership requirements for unfilled non-pioneer areas after three years.

Application Process

  • First-come-first-served registration until measured capacity filled.
  • Selection criteria favor Filipino ownership, integration, experience, costs, exchange impacts, labor use, equity spread, competition, and public participation.
  • Preference to enterprises expanding or integrating existing facilities.
  • Appeals to National Economic Council and then the President.

Certification of Registration

  • Issuance of certificate specifying enterprise name, investment area, activity, capacity, terms.

General Provisions

  • Directors' cap at 15.
  • Dual voting share structure to ensure Filipino majority control.
  • Marketing affiliates wholly Filipino owned may be established under conditions.

Other Incentives Laws

  • Coordination with other incentive laws to avoid duplication.
  • Enterprises may avail incentives from multiple laws, but not duplicative benefits for same capacity.

Penal Provisions

  • Violations punishable by fines or imprisonment.
  • Deportation of foreign offenders.
  • Government officials prohibited from representing parties in transactions with the Board.
  • Additional sanctions including dismissal for offending officials.

Applicability and Interpretation

  • Existing enterprises entitled to registration and benefits prospectively.
  • Benefits limited to preferred/pioneer activities in multi-area enterprises.
  • Doubts resolved in favor of investors and registered enterprises.

Separability Clause

  • Unconstitutional provisions do not invalidate entire Act.

Appropriations

  • Initial appropriation of two million pesos for Board operation.
  • Subsequent funding from General Appropriations Act.

Repealing Clause

  • Repeals inconsistent laws and regulations.

Effectivity

  • The Act takes effect upon approval.

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