VELASCO, PUNZALAN and COMPANY

(Formerly Velasco Aguirre and Company)

CERTIFIED PUBLIC ACCOUNTANTS
LG 21 Cityland Dela Rosa Condominium, 7648 Dela Rosa St., Pio Del Pilar, Makati City 1230
Tel (632) 819-1427 | Telefax (632) 817-6395 | Email velascoaguirre@outlook.ph;nestor@vmccpa.com Web http://vpccpas.weebly.com
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NOTICE NO.: 2019-003

TO: ALL CLIENTS

SUBJECT: IMPLEMENTING RULES AND REGULATIONS OF REPUBLIC ACT (RA) NO.

11213 OTHERWISE KNOWN AS THE “TAX AMNESTY ACT OF 2019”- An Act Enhancing
Revenue Administration and Collection by Granting an Amnesty on All Unpaid Internal Revenue
Taxes Imposed by the National Government for Taxable Year 2017 and Prior Years with Respect to
Estate Tax, Other Internal Revenue Taxes, and Tax on Delinquencies

NOTICE

On February 14, 2019, Pres. Rodrigo R. Duterte signed into law RA 11213 granting Estate Tax
Amnesty and Tax Amnesty on Delinquencies.

Pursuant thereto, the BIR issued RR No. 04-2019 dated April 5, 2019 which contains the
guidelines for implementing the tax amnesty on delinquency provision under the Tax Amnesty Act of
2019. It later issued RR No. 06-2019 dated May 29, 2019 which contains the guidelines for implementing
the tax amnesty on estate tax provision also embodied in the same Act.

The coverage of RR No. 04-2019 is indicated in Section 3, and corresponding tax rates in
Section 4 thereof, which includes:
A. Delinquent Accounts – 40% of the basic tax assessed;
1. Delinquent Accounts with application for compromise settlement either on the basis
of (a) doubtful validity of the assessment or (b) financial incapacity of the taxpayer,
whether the same was denied by or still pending with the Regional Evaluation Board
(REB) or the National Evaluation Board (NEB), on or before the effectivity of this
Regulations;
2. Delinquent Withholding Tax liabilities arising from non-withholding of tax; and
3. Delinquent Estate Tax liabilities.

B. With pending criminal cases with the Department of Justice (DOJ)/Prosecutor’s Office or
the courts for tax evasion and other criminal offenses under Chapter II of Title X and
Section 275 of the Tax Code, as amended, with or without assessments duly issued – 60%
of the basic tax assessed;
C. With final and executory judgment by the courts on or before the effectivity of these
Regulations – 50% of the basic tax assessed; and
D. Withholding tax liabilities of withholding agents arising from their failure to remit
withheld taxes – 100% of the basic tax assessed.

As provided under RA 11213 Section 6, Estate Tax Amnesty can be availed within two (2)
years from the effectivity of the Implementing Rules and Regulations issued by the BIR. On the
other hand, Section 19 of the same law provides that Tax Amnesty on Delinquencies can be
availed within one (1) year from the effectivity of the Implementing Rules and Regulations.
 Estate Tax Amnesty shall cover the estate of the decedents who died on or before December 31,
2017, with or without assessments duly issued. Related BIR issuances are as follows:

REVENUE REGULATIONS
Issuance No. Subject Matter Date of Issue
RR No. 6-2019 Implements the provisions of Estate Tax Amnesty May 31, 2019
pursuant to the provisions of Republic Act No.
11213 (Tax Amnesty Act)
(Published in Malaya Business Insight on May 31,
2019)
Revenue Memorandum Circulars
RMC No. 26-2019 Circularizes RA No. 11213 entitled "An Act February 26, 2019
Enhancing Revenue Administration and Collection
by Granting an Amnesty on All Unpaid Internal
Revenue Taxes Imposed by the National
Government for Taxable Year 2017 and Prior Years
with Respect to Estate Tax, Other Internal Revenue
Taxes, and Tax on Delinquencies", together with
the Veto Message of President Rodrigo R. Duterte
RMC No. 68-2019 Provides clarification on certain issues relative to July 5, 2019
Estate Tax Amnesty under Title II of RA No. 11213
(Tax Amnesty Act)
REVENUE MEMORANDUM ORDERS
RMO No. 19-2019 Creates the Alphanumeric Tax Code for Tax April 29, 2019
Amnesty on Estate and Delinquencies pursuant to
the implementation of RA No. 11213 (Tax Amnesty
Act)
RMO No. 33-2019 Prescribes the policies, guidelines and procedures June 27, 2019
in the processing and monitoring of Estate Tax
Amnesty availment pursuant to RA No. 11213 (Tax
Amnesty Act) as implemented by RR No. 6-2019
and issuance of the corresponding electronic
Certificates Authorizing Registration (eCARs)

On the other hand, Tax Amnesty on Delinquencies shall cover all national internal revenue
taxes such as, but not limited to, income tax, withholding tax, capital gains tax, excise tax and
documentary stamp tax collected by the Bureau of Internal Revenue, including value-added tax and
excise taxes collected by the Bureau of Customs for taxable year 2017 and prior years. Related BIR
issuances are as follows:

REVENUE REGULATIONS
Issuance No. Subject Matter Date of Issue
RR No. 4-2019 Implements the rules and regulations of the Tax April 8, 2019
Amnesty Act, providing for the guidelines on the
processing of Tax Amnesty Application on Tax
Delinquencies
Revenue Memorandum Circulars
RMC No. 26-2019 Circularizes RA No. 11213 entitled "An Act February 26, 2019
Enhancing Revenue Administration and Collection
by Granting an Amnesty on All Unpaid Internal
Revenue Taxes Imposed by the National
 Government for Taxable Year 2017 and Prior Years
with Respect to Estate Tax, Other Internal Revenue
Taxes, and Tax on Delinquencies", together with
the Veto Message of President Rodrigo R. Duterte
RMC No. 57-2019 Clarifies certain issues on Tax Amnesty on May 31, 2019
Delinquencies pursuant to the provisions of Tax
Amnesty Act.
REVENUE MEMORANDUM ORDERS
RMO No. 19-2019 Creates the Alphanumeric Tax Code for Tax April 29, 2019
Amnesty on Estate and Delinquencies pursuant to
the implementation of RA No. 11213 (Tax Amnesty
Act)
RMO No. 23-2019 Prescibes the policies, guidelines and procedures in May 9, 2019
the processing of applications for Tax Amnesty on
Delinquencies pursuant to RA No. 11213 (Tax
Amnesty Act)

RR No. 4-2019 Sec. 5 sets forth the manner (which include the documentary requirements as
well as place of filing) of availment of Tax Amnesty on Delinquencies. Section 6 of the same Revenue
Regulation is noteworthy; it gives the BIR a period of fifteen (15) calendar days from submission of the
documentary requirements (i.e. those enumerated under Section 5) to act on it. Otherwise, the
“stamped-received” duplicate copies of the Tax Amnesty Return (TAR) and Acceptance Payment Form
(APF) which are among those requirements indicated under Section 5, shall be deemed as sufficient
proof of availment, or in short, deemed approved by the BIR.

Please be guided accordingly.