Title
Implementing Tax Incentives for Subic Zone
Law
Bir Revenue Regulations No. 1-95
Decision Date
Jan 24, 1995
BIR Revenue Regulations No. 1-95 establishes tax incentives for registered enterprises within the Subic Special Economic Zone, promoting foreign investment and economic development through exemptions from customs duties and internal revenue taxes on imports and sales.
A

Declaration of Policy

  • State policy to develop Subic Special Economic Zone as a self-sustaining industrial, commercial, financial, and investment center.
  • Objective: generate employment and attract productive foreign investments.

Definitions

  • "Act": Republic Act No. 7227 (Bases Conversion and Development Act).
  • "SBMA": Subic Bay Metropolitan Authority.
  • "Zone": Subic Special Economic and Freeport Zone, including City of Olongapo, Municipality of Subic, and former Subic Bay Naval Base area.
  • "Secured Area": The fenced former naval base; the only fully tax and duty-free zone within the Zone.
  • Customs terms and distinctions between Domestic and Foreign Articles explained.
  • Definitions for Resident, Registered Enterprise, Transshipment, Retail Sale, Foreign Exchange, and Gross Income Earned.
  • Specific allowable deductions for calculating gross income for manufacturing, service enterprises, and financial institutions.

Tax Exemptions and Incentives

  • Exemptions from customs duties and national internal revenue taxes on importations of raw materials, capital goods, and equipment imported into the Secured Area.
  • Consumption items are tax free only if consumed within the Secured Area.
  • Residents and Filipinos have specific privileges to bring out limited value consumer items duty-free.
  • Duty-free shops to operate under SBMA and Customs regulations with strict controls.
  • Foreign tourists, balikbayans, and returning residents have similar tax-free privileges subject to control systems.
  • Exemption from VAT, gross receipts tax, ad valorem, excise, franchise, and other percentage taxes on business within the Secured Area.
  • Preferential income tax treatment on earnings from operations inside the Secured Area or foreign sources.
  • Zero-rating of purchases from Customs Territory by SBMA and accredited enterprises for VAT purposes.
  • Enterprises may earn up to 30% income from Customs Territory without losing tax incentive status.
  • Carriers transporting goods between Secured Area and Customs Bonded Warehouses must post bonds.
  • Manufactured articles exported from Secured Area subject to import regulations upon return to Customs Territory.
  • Non-registered enterprises in the Secured Area do not enjoy these incentives.

Customs Duties and Taxation on Removal of Goods

  • Foreign articles removed to Customs Territory subject to regular customs duties and taxes.
  • Articles admitted from Customs Territory to the Secured Area under permit are zero-rated.
  • Foreign articles used by subcontractors in production may move under bond with guarantees.
  • Foreign articles sold within Secured Area to residents or tourists exempt from duties if consumed within or exported.
  • Duty-free consumer purchase limits and conditions clarified.
  • Illegal removal of foreign articles in commercial quantities subject to seizure and criminal penalties.

Fiscal Obligations and Tax Liabilities

  • Registered enterprises pay a combined 5% of gross income earned: 3% to National Government, 1% to local government units, 1% to a special development fund.
  • 3% paid to the National Government considered for foreign tax credit claims.
  • Enterprise responsible for safekeeping and accounting of articles received.
  • Missing or unaccounted articles presumed unlawfully transferred into Customs Territory and taxed accordingly.
  • Registered enterprises must comply with SBMA and Customs Operations Manuals.
  • Enterprises act as withholding agents for employee compensation and other income payments.
  • Preferential tax rates apply to interest income from deposits of registered enterprises in Secured Area.

Return Filing and Tax Payment Procedures

  • 5% tax based on gross income earned payable quarterly and annually.
  • Periodic tax returns filed in duplicate, signed and sworn by responsible corporate officers.
  • Returns filed with the Revenue District Office or accredited bank within the Zone.
  • Tax return filing and payment dates follow National Internal Revenue Code rules and applicable regulations.

Allocation and Disposition of Tax Revenues

  • Tax proceeds divided into general fund (3%), local governments (1%), and special development fund (1%) for surrounding municipalities.

Record Keeping and Auditing

  • Registered enterprises must keep accurate and regular books of accounts and related documents.
  • Records subject to inspection and audit by authorized officers of SBMA and Bureau of Internal Revenue.

Applicability of Existing Laws

  • Provisions of National Internal Revenue Code on keeping books and records, penalties, and offenses apply to enterprises in Secured Area.

Effectivity

  • Regulations take effect fifteen days after publication in Official Gazette or newspaper of general circulation, whichever is earlier.

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