Title
Tax Exemptions for Rural Banks per R.A. 7353
Law
Kri Revenue Regulation No. 16-93
Decision Date
Apr 22, 1993
R.A. No. 7353 establishes tax exemptions for rural banks, allowing them to operate free from various taxes for five years while outlining their responsibilities as withholding agents and the penalties for non-compliance by judicial officials.

Law Summary

Taxes Covered by Exemption

  • Exemption applies to all rural banks created under the Act and those operational as of April 2, 1992.
  • Exemption covers all taxes, fees, and charges except:
    • Corporate income tax.
    • Local taxes, fees, and charges.
  • Corporate income tax liabilities include:
    • 35% corporate income tax (Section 24(a), NIRC).
    • 20% final withholding tax on specific interest income (Section 24(e)(1), NIRC).
    • Creditable expanded withholding tax on property transactions (RMC 7-90).
    • Capital gains tax on shares and foreclosure sales (Section 24(e)(2), NIRC; Revenue Memorandum Order No. 6-92).
    • Other income taxes under Title II, NIRC.
  • Gross receipts tax exemption under Section 119, NIRC.
  • Exemption from documentary stamp tax for loans or transactions up to ₱50,000.
  • Notary public services for rural banks' loans under ₱50,000 are free of charge.
  • Registers of Deeds must accept documents related to these loans free from charges and documentary stamp tax.

Liability for Documentary Stamp Tax

  • Documentary stamp tax applies to loan amounts exceeding ₱50,000.
  • For consolidated mortgage assignments, DST applies only to the amount exceeding ₱50,000 on each mortgage.
  • The person executing the document is liable for the tax.
  • If one party is exempt, the other party must pay the tax.

Rural Banks Acting as Agents of National Banks

  • Rural banks acting as agents of PNB, LBP, DBP in areas without branches are subject to tax if their principal banks are taxed.
  • Such rural banks must follow accreditation guidelines as per Section 25 of the Act.

Rural Banks as Withholding Agents

  • Rural banks act as withholding agents if they:
    • Employ personnel subject to withholding tax on compensation.
    • Make payments subject to expanded withholding tax to individuals or corporations.
  • Comply with relevant NIRC sections and Revenue Regulations.

Liability of Judges and Registers of Deeds

  • City or municipal trial court judges or Registers of Deeds demanding or accepting unauthorized fees related to rural banks' transactions are penalized.
  • Penalties include fines up to ₱1,000, imprisonment up to one year, or both.

Period of Exemption

  • Five-year exemption period for rural banks from all taxes except those specified in Section 2(A).
  • For banks created after the Act, period counted from commencement of operations.
  • For existing banks, period counted from April 2, 1992 (date of approval).
  • Commencement date defined as registration date with SEC or issuance of authority to operate by the Monetary Board, whichever is later.
  • Effective date of the Act is June 9, 1992, following official publication.

Repealing Clause

  • All inconsistent regulations or orders contrary to these provisions are modified, amended, or revoked.

Effectivity of Regulations

  • Regulations take effect 15 days after publication in a widely circulated newspaper.

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