Title
Reverting Tax Filing Venue for Large Taxpayer Realty
Law
Bir Revenue Regulations No. 5-2009
Decision Date
Mar 16, 2009
BIR Revenue Regulations No. 5-2009 mandates that large taxpayers must file capital gains tax, creditable withholding tax, and documentary stamp tax returns, as well as make payments, at the Revenue District Office where the real property is located, ensuring uniformity and efficiency in processing real estate transactions.
A

Policy Statement and Background

  • Prior rule (RR No. 8-98): Venue determined by property location for all taxpayers.
  • Amendment (RR No. 4-2008) centralized filing at Large Taxpayers Service (LTS) Office for large taxpayers only.
  • Caused confusion due to changing taxpayer classification.
  • Reversion aims for uniformity and facilitates physical inspection of property before issuing Certificate Authorizing Registration (CAR)/Tax Clearance Certificate (TCL).

Time and Place for CGT and DST on Capital Assets

  • CGT Return (BIR Form 1706) and payment due within 30 days of transaction.
  • Filing/payment at AAB in RDO with jurisdiction over property location.
  • DST Return (BIR Form 2000-OT) due within 5 days after month-end when document was executed.
  • Applies to both large and non-large taxpayers.
  • Includes taxable foreclosure sales.

Time and Place for CWT and DST on Ordinary Assets

  • Creditable Withholding Tax Return (BIR Form 1606) filed by withholding agent/buyer within 10 days after month-end.
  • Payment and filing at AAB within jurisdiction of property's RDO.
  • DST filing as per capital assets requirements.
  • Applies to large and non-large taxpayers, including taxable foreclosure sales.
  • Subject to specific provisions of RR 2-98 and Electronic Filing and Payment System (EFPS) when applicable.

Issuance of CAR/TCL

  • CAR/TCL issued by RDO where property is located upon proof of payment of CGT or CWT and DST.
  • RDO must notify seller's RDO for post-audit of tax returns to ensure full tax compliance on ordinary asset sales.
  • Details of CAR recorded on reverse of sale/exchange documents by revenue officers.
  • CAR/TCL is valid for one year; may be revalidated up to two years total.
  • Register of Deeds prohibited from accepting CAR/TCL with erasures or alterations.

Validity of Revenue Regulations No. 24-2002

  • Regulations governing data submission by Land Registration Authority, Register of Deeds, and Assessors to BIR remain fully effective.
  • Covers documentation annotation, issuance, recording, and monitoring of CAR.
  • Ensures all internal revenue taxes on real property transfers are paid.

Transitory Provisions for Pre-Effective Transactions

  • Cash or deferred payments over 25%: CAR/TCL processed by LTS Office if taxes already paid.
  • Installment sales with full payment and taxes paid: CAR/TCL processed by LTS Office.
  • Installment sales without full payment: Remaining payments and tax filings transferred to RDO where property is located.

Repealing Clause

  • All conflicting revenue rules and regulations or parts are amended, modified, or revoked.

Effectivity Clause

  • Regulations become effective 15 days after publication in a newspaper of general circulation.

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