Title
RPT relief for IPPs under BOT contracts
Law
Executive Order No. 117
Decision Date
Jul 24, 2020
Rodrigo Roa Duterte's Executive Order No. 117 mandates the reduction and condonation of real property taxes and penalties for Independent Power Producers under Build-Operate-Transfer contracts, ensuring their financial stability and continued contribution to the energy sector.
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Dispute Over Real Property Tax (RPT) for Independent Power Producers (IPPs)

  • Some local government units (LGUs) argue IPPs, which are not GOCCs, are ineligible for GOCC tax exemptions.
  • LGUs have threatened enforcement actions such as levy and property auction against IPPs for RPT dues.

Financial and Economic Implications of RPT Collection on IPPs

  • Much of the RPT is contractually assumed by the National Power Corporation or Power Sector Assets and Liabilities Management Corporation, backed by the National Government’s full faith and credit.
  • LGUs’ collection efforts may impose significant direct liabilities on GOCCs, jeopardizing financial stability and fiscal consolidation aims.
  • Potential consequences include unstable energy prices, economic losses, cross-defaults, and adverse effects on various sectors.

Importance of IPPs to National and Local Governments and Energy Grid Stability

  • IPPs substantially contribute to national and local tax revenues.
  • They provide approximately 3,100 megawatts of grid capacity.
  • Closure or non-operation of IPPs could lead to substantial government losses, costly alternative power sources, or rotating power outages.

Presidential Authority to Condone or Reduce Real Property Taxes

  • Section 277 of RA No. 7160 authorizes the President to condone or reduce RPT and interest when public interest warrants.
  • Section 17, Article VII of the 1987 Constitution vests the President with control over executive departments and offices.

Reduction and Condonation of RPT Liabilities (Section 1)

  • RPT liabilities for calendar year 2019 on property, machinery, and equipment used by IPPs under Build-Operate-Transfer (BOT) or similar contracts with GOCCs are reduced.
  • Tax dues recalculated based on 15% assessment level of the fair market value, depreciated at 2% per annum.
  • Interests and penalties on unpaid RPT liabilities are fully condoned.
  • IPPs are relieved from paying such interests and penalties.

Application of Overpayments to Future Liabilities (Section 2)

  • Any RPT payments exceeding the reduced amounts will be credited against future RPT liabilities.

Mandatory Compliance by Government Entities (Section 3)

  • All government departments, agencies, GOCCs, and LGUs must comply strictly with this Order.
  • Non-compliance will be sanctioned under civil service laws and regulations.

Repeal of Inconsistent Rules (Section 4)

  • Any rules or regulations contradictory to the Order are revoked, amended, or modified accordingly.

Separability Clause (Section 5)

  • Invalidity or unconstitutionality of any provision does not affect the validity of the other provisions.

Effectivity (Section 6)

  • The Order takes effect immediately upon publication in a newspaper of general circulation.

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