General Tax Amnesty Act of 2026

Sentate Office of the Secretatp TWENTIETH CONGRESS OF THE REPUBLIC OF THE PHILIPPINES First Regular Session ) APR 13 P3:30 RECEIVED BY: _ SENATE Senate Bill No. 2038 Introduced by Senator Erwin T. Tulfo AN ACT DECLARING A ONE-TIME AMNESTY ON ALL UNPAID INTERNAL REVENUE TAXES IMPOSED BY THE NATIONAL GOVERNMENT FOR TAXABLE YEAR 2024 AND PRIOR YEARS EXPLANATORY NOTE The power to tax is the lifeblood of the State. Yet, the effectiveness of taxation depends not only on enforcement but equally on voluntary compliance, simplicity of rules, and the credibility of the tax system. Persistent gaps in tax administration and compliance coupled with complex requirements have limited the full potential of revenue collection. This bill entitled General Tax Amnesty Act of 2026 aims to provide a one-time opportunity for taxpayers to settle all unpaid internal revenue tax liabilities for taxable year 2024 and prior years. The measure aims to broaden the tax base, improve the accuracy of taxpayer data, and enhance future tax administration. To encourage wider participation, the bill adopts a dual-mode amnesty system. Taxpayers may opt for a simplified declaration based on total assets subject to a minimal rate, or a more detailed declaration based on net worth subject to graduated rates and minimum payments.

This approach balances ease of compliance with the need for more reliable and comprehensive disclosures. At the same time, the measure incorporates safeguards to ensure integrity, including penalties for fraud and material underdeclaration, a defined verification period, clear conditions for the availment and finality of the amnesty, and guarantee of confidentiality to encourage truthful disclosure. By providing a mechanism to regularize past tax obligations while strengthening the tax system moving forward, this measure seeks to promote compliance, improve revenue collection, and restore trust between the State and taxpayers. In view of the foregoing, the immediate passage of this bill is earnestly sought. ERWIN T. TULFO

Senate Office of the Secretary TWENTIETH CONGRESS OF THE REPUBLIC OF THE PHILIPPINES APR 13 P3:30 First Regular Session RECEIVED BY: SENATE Senate Bill No. 2038 Introduced by Senator Erwin T. Tulfo AN ACT DECLARING A ONE-TIME AMNESTY ON ALL UNPAID INTERNAL REVENUE TAXES IMPOSED BY THE NATIONAL GOVERNMENT FOR TAXABLE YEAR 2024 AND PRIOR YEARS Be it enacted by the Senate and the House of Representatives of the Philippines in Congress assembled:

SECTION 1. Short Title. - This Act shall be known as the

2 "General Tax Amnesty Act of 2026".

SEC. 2. Declaration of Policy. - It is hereby declared the policy

5 of the State to protect and enhance revenue administration and 6 collection, promote equity in taxation, and simplify tax compliance 7 requirements in order to strengthen voluntary compliance and improve overall tax efficiency. Towards this end, the State shall: (a) Broaden the tax base through the grant of a one-time general tax amnesty covering all unpaid internal revenue tax obligations, 14 thereby cleansing, updating, and improving the integrity of the Bureau 15 of Internal Revenue database; and

(b) Provide a more equitable and efficient tax system by 2 adopting simplified procedures for availing tax amnesty, including the use of streamlined forms and information technology systems.

SEC. 3. Definitions of Terms. - As used in this Act:

(a) Statement of Assets, Liabilities, and Net Worth refers to a declaration of a taxpayer's assets, liabilities, and net worth as of December 31, 2024, which shall include: 1) Assets, whether within or without the Philippines, real or personal, tangible or intangible, and whether or not used in trade or business: Provided, That property other than money shall be valued at the cost at which the property was acquired: Provided, further, That foreign currency- denominated assets and/or securities shall be valued at the prevailing exchange rate as of the date of the declaration; 2) Liabilities, consisting of all existing obligations that are legitimate, enforceable, and duly documented, whether secured or unsecured, and whether or not incurred in trade or business; and 3) Net worth, which shall be the difference between the total assets and total liabilities. (b) Statement of Total Assets refers to a declaration of the taxpayer's aggregate assets whether within or without the Philippines, real or personal, tangible or intangible, or ordinary or capital.

SEC. 4. Coverage. - There is hereby authorized and granted a tax

amnesty, hereinafter called General Tax Amnesty, which shall cover all national internal revenue taxes such as, but not limited to, income tax, withholding tax, capital gains tax, donor's tax, value-added tax, other percentage taxes, excise tax, and documentary stamp tax collected by the Bureau of Internal Revenue (BIR), including value- 37 added tax and excise taxes collected by the Bureau of Customs for

1 taxable year 2024 and prior years, with or without assessments duly 2 issued therefor, that have remained unpaid: Provided, however, That 3 the General Tax Amnesty hereby authorized and granted shall not 4 cover estate tax and shall not apply to persons or cases enumerated under Section 10 of this Act.

SEC. 5. Entitlement Under the General Tax Amnesty. - Any

person, whether natural or juridical, who is covered by this law, may 9 enjoy the immunities and privileges of the General Tax Amnesty upon 10 payment of an amnesty tax, under either of the following modes at the taxpayer's option: (a) Total Assets-Based Amnesty. - At the rate of two percent (2%) based on the taxpayer's total assets as of December 31, 2024, as declared in the Statement of Total Assets; or (b) Net Worth-Based Amnesty. - Based on the taxpayer's total net worth as of December 31, 2024, as declared in the Statement of Assets, Liabilities, and Net Worth filed pursuant to Section 6 hereof and in accordance with the following schedule of amnesty tax rates and minimum amnesty tax payments required: 1) Individual (whether resident or nonresident citizens, including resident or nonresident aliens), Trusts, and Estates ... Five percent (5%) or PHP 100,000.00, whichever is higher 2) Corporations (i) With subscribed capital of above PHP 950 million ... Five percent (5%) or PHP 1,300,000.00, whichever is higher

(ii) With subscribed capital of above PHP 920 million up to PHP 950 million ..... Five percent (5%) or PHP 650,000.00, whichever is higher (ini) With subscribed capital of PHP 5 million up to PHP 920 million Five percent (5%) or PHP 350,000.00, whichever is higher (iv) With subscribed capital of below PHP 5 million ... Five percent (5%) or PHP 150,000.00, whichever is higher 3) Other juridical entities, including, but not limited to, cooperatives and foundations, that have become taxable as of December 31, 2024 ... Five percent (5%) or PHP 100,000.00, whichever is higher Provided, That, in the case of a taxpayer availing of the amnesty whose net worth is zero or negative, such taxpayer may avail of the amnesty upon payment of the applicable minimum amnesty tax. The option exercised by the taxpayer under this Section shall be irrevocable upon filing of the required declaration and payment of the amnesty tax. All declarations made under either mode shall be complete, truthful, and duly supported by available records

SEC. 6. Availment of the General Tax Amnesty; When and Where

to File and Pay. - Any person, whether natural or juridical, who intends to avail of the General Tax Amnesty shall, within one (1) year from the effectivity of the Implementing Rules and Regulations (IRR) of this

1 Act, file, either electronically or manually, with any authorized agent 2 bank, Revenue District Office through Revenue Collection Officer, or authorized tax software provider, a sworn General Tax Amnesty Return accompanied by a either a notarized Statement of Total Assets or notarized Statement of Assets, Liabilities, and Net Worth, as 6 applicable, as of December 31, 2024, in such form as may be prescribed under the IRR. The amnesty tax shall be paid at the time of filing of the return, 10 through any of the authorized modes prescribed herein. The Revenue 11 District Officer shall issue and endorse an Acceptance Payment Form, 12 in such form as may be prescribed in the IRR authorizing the authorized agent bank, the Revenue District Office through the Revenue Collection Officer or authorized software provider to accept the amnesty tax payment. Availment of the General Tax Amnesty within the periods indicated below shall entitle the taxpayer to the following reductions in the amnesty tax due: (a) If paid on or before the end of the third calendar month from the effectivity of the IRR.........20%; (b) If paid after the end of the third calendar month until the end of the sixth calendar month from the effectivity of the IRR.........15%; and (c) If paid after the end of the sixth calendar month until the end of the ninth calendar month from the effectivity of the IRR..... ..10%. Provided, That, notwithstanding Republic Act No. 1405, otherwise known as the "Bank Secrecy Law", Republic Act No. 6426, otherwise known as the "Foreign Currency Deposit Act of the Philippines," and other general or special laws, and solely for purposes of verifying the accuracy and completeness of the tax declarations made under this Act, the Commissioner of Internal Revenue may, upon

1 a finding of prima facie discrepancy or material underdeclaration, inquire into and obtain information on the taxpayer's bank deposits and financial accounts held by domestic and foreign financial institutions. The Commissioner may likewise exchange information with foreign tax authorities in accordance with duly ratified international agreements subject to applicable laws on confidentiality and data privacy. Such authority shall be exercised only within one (1) year from the filing of the General Tax Amnesty Return, and only to the extent necessary for validation under this Act.

SEC. 7. Contents of the Statement of Total Assets or Statement of

12 Assets, Liabilities, and Net Worth. - (a) The Statement of Total Assets shall contain a declaration of the taxpayer's total assets, as of December 31, 2024, as follows: 1) Assets within or without the Philippines, whether real or personal, tangible or intangible, whether or not used in trade or business: (i) Real properties shall be accompanied by a description of their classification, exact location, and valued at the actual acquisition cost, zonal value, or the Schedule of Market Values at the time of acquisition, whichever is higher, if acquired by purchase; Provided, That if the real properties are acquired through inheritance or donation, it shall be valued at the actual price as stated in the real property transaction documents, zonal value, or the Schedule of Market Values, whichever is higher; (ii) Personal properties other than money, shall be accompanied by a specific description of the kind and number of assets or other investments, indicating the acquisition cost less the accumulated depreciation or amortization, or the corresponding

book value for shares of stock, in proper cases, if acquired by purchase, or the fair market price or value at the date of the Statement of Total Assets, if acquired through inheritance or donation; (iii) Assets denominated in foreign currency shall be converted into the corresponding Philippine currency equivalent, at the rate of exchange prevailing as of the date of the Statement of Total Assets; and (iv) Cash on hand and in bank in peso as of the date of the Statement of Total Assets, as well as cash on hand and in bank in foreign currency, converted to Philippine peso at the rate of exchange prevailing as of the date of the Statement of Total Assets. (b) The Statement of Assets, Liabilities, and Net Worth shall contain a true and complete declaration of assets, liabilities, and net worth of the taxpayer as of December 31, 2024, as follows: 1) Assets within or without the Philippines, whether real or personal, tangible or intangible, whether or not used in trade or business: (i) Real properties shall be accompanied by a description of their classification, exact location, and valued at the actual acquisition cost, zonal value, or the Schedule of Market Values at the time of acquisition, whichever is higher, if acquired by purchase: Provided, That if the real properties are acquired through inheritance or donation, it shall be valued at the actual price as stated in the real

property transaction documents, zonal value, or the Schedule of Market Values, whichever is higher; (ii) Personal properties other than money, shall be accompanied by a specific description of the kind and number of assets (e.g., automobiles, shares of stock, etc.) or other investments, indicating the acquisition cost less the accumulated depreciation or amortization, or the corresponding book value for shares of stock, in proper cases, if acquired by purchase, or the fair market price or value at the date of the Statement of Assets, Liabilities, and Net Worth, if acquired through inheritance or donation; (iii Assets denominated in foreign currency shall be converted into the corresponding Philippine currency equivalent, at the rate of exchange prevailing as of the date of the Statement of Assets, Liabilities, and Net Worth; and (iv) Cash on hand and in bank in peso as of the date of the Statement of Assets, Liabilities, and Net Worth, as well as cash on hand and in bank in foreign currency, converted to Philippine peso at the rate of exchange prevailing as of the date of the Statement of Assets, Liabilities, and Net Worth. 2) All existing liabilities, which are legitimate and enforceable, secured or unsecured, whether or not incurred in trade or business, disclosing or indicating clearly the name and address of the creditor and the amount of the corresponding liability. Foreign currency denominated liabilities are converted to Philippine peso at the rate of

exchange prevailing as of the date of the Statement of Assets, Liabilities, and Net Worth. 3) The total net worth of the taxpayer, which shall be the difference between the total assets and total liabilities.

SEC. 8. Presumption of Correctness of the Statement of Total

7 Assets, and Statement of Assets, Liabilities, and Net Worth. - The 8 Statement of Total Assets or the Statement of Assets, Liabilities, and Net Worth, filed at the option of the taxpayer shall be presumed true 10 and correct, unless it is established that the amount of total assets or net 11 worth declared therein is understated by at least thirty percent (30%) as 12 may be determined by the Commissioner of Internal Revenue: 13 Provided, That the Commissioner of Internal Revenue shall make such determination within one (1) year from the filing of the General Tax 15 Amnesty Return. Upon full payment of the tax, the taxpayer shall submit the 18 Acceptance Payment Form and the General Tax Amnesty Return to the 19 appropriate Revenue District Office. Compliance with these 20 requirements shall constitute full availment of the General Tax 21 Amnesty. The BIR shall issue a Certificate of Availment within fifteen (15) 24 calendar days from submission of complete documents. In case of failure to issue such certificate within the prescribed period, the duly stamped received copies of the Acceptance Payment Form and General Tax Amnesty Return shall serve as sufficient and 29 conclusive proof of availment.

SEC. 9. Immunities and Privileges. -

(a) Any taxpayer who validly avails of the General Tax Amnesty and fully complies with all the conditions set forth in this Act shall, upon payment of the amnesty tax, be entitled to the following immunities and privileges: 1) With respect to the years covered by the tax amnesty, the taxpayer shall be immune from the payment of all covered taxes, as well as additions thereto, and from all corresponding civil, criminal, and administrative liabilities and penalties under the National Internal Revenue Code of 1997, as amended, arising from the failure to pay such taxes, including related investigations, audits, or proceedings insofar as they pertain to the assets, liabilities, net worth, covered by the amnesty; 2) Any information or data contained in, derived from, or provided by a taxpayer in the General Tax Amnesty Return, Statement of Total Assets or Statement of Assets, Liabilities, and Net Worth, including all supporting documents, shall be confidential in nature and shall not be used in any investigation or prosecution before any judicial, quasi judicial, and administrative body: Provided, That the taxpayer may invoke the same as a defense, whenever appropriate; and 3) The books of accounts and other records of the taxpayer for the years covered by the amnesty shall not be examined by the BIR: Provided, That the Commissioner of Internal Revenue may authorize in writing the examination of the said books of accounts and other records for purposes of verifying claims for tax refund, tax credit (excluding those

withheld on wages), tax incentives, or exemptions under existing laws. (b) The immunities and privileges under this Section shall not apply: 1) When the taxpayer failed to file a General Tax Amnesty Return and the corresponding Statement of Total Assets, or Statement of Assets, Liabilities, and Net Worth, as the case may be; 2) Where the amount of total assets or net worth is proven to be understated by at least thirty percent (30%) in accordance with Section 8 of this Act; or 3) In cases of fraud or willful misrepresentation regardless of the extent of the under-declaration. Upon full compliance with all the conditions set forth in this Act and payment of the corresponding amnesty tax, the tax amnesty granted under this Act shall become final and irrevocable.

SEC. 10. Exceptions. - The General Tax Amnesty under this Act

shall not extend to the following: (a) Withholding tax agents who failed to remit taxes withheld to the BIR; (b) Taxpayers with cases pending in appropriate courts or tribunals at the time of application for the General Tax Amnesty involving: 1) Cases falling under the jurisdiction of the Presidential Commission on Good Government;

2) Unexplained or unlawfully acquired wealth under Republic Act No. 3019 , otherwise known as the "Anti-Graft and Corrupt Practices Act" ', and Republic Act No. 7080, otherwise known as the "Anti-Plunder Law"; 3) Violations of Republic Act No. 9160, otherwise known as the "Anti- Money Laundering Act" ', as amended; 4) Tax evasion and other criminal offenses under Chapter Il of Title X of the National Internal Revenue Code of 1997, as amended; and 5) Felonies involving frauds, illegal exactions and transactions, and malversation of public funds or property under Chapters III and IV of Title VII of the Revised Penal Code; (c) Delinquencies, assessments, and tax liabilities subject of cases that have become final and executory;

SEC. 11. Declaration under Penalties of Perjury. - All

declarations, returns, and statements required under this Act shall contain a written statement that the same are made under the penalties of perjury. Any person who willfully files a declaration, return, or statement containing information that is false or incorrect as to any material matter shall, upon conviction, be subject to the penalties prescribed for perjury under the Revised Penal Code. In case a false or fraudulent return is willfully made, the penalty to be imposed shall be equivalent to fifty percent (50%) of the tax due, or of the deficiency tax if payment has been made on the basis of such return prior to the discovery of the falsity or fraud: Provided, That 33 failure to declare total assets or net worth resulting in an understatement of at least thirty percent (30%), as determined by the Commissioner of Internal Revenue in accordance with rules and regulations issued by the Secretary of Finance, shall constitute prima facie evidence of a false or fraudulent return: Provided, further, That if the offender is a juridical

entity, the penalties shall be imposed on the entity's responsible officers, such as, but not limited to, the president, chief executive officer, general manager, or partner directly responsible, or members of the board of directors, others who have beneficial interest in the 5 juridical entity, and employees responsible for the violation.

SEC. 12. Confidentiality and Non-use of Information and Data

8 in the Statement of Total Assets and Statement of Assets, Liabilities, 9 and Net Worth. - Any information or data contained in, derived from, 10 or provided by a taxpayer in the General Tax Amnesty Return, Statement of Total Assets or Statement of Assets, Liabilities, and Net 12 Worth, including all supporting documents, shall be confidential in 13 nature and shall not be used in any investigation or prosecution before any judicial, quasi-judicial, and administrative body. Such information shall be used solely for purposes of determining compliance with the provisions of this Act, except in cases of fraud, misrepresentation, or material underdeclaration of assets.

SEC. 13. Information Management System. - For purposes of

enhancing revenue administration, collection and policy formulation, the Department of Finance, in coordination with the BIR, Land Registration Authority, Department of Trade and Industry, Securities and Exchange Commission, Land Transportation Office, and other agencies concerned, shall institute an Information Management Program for the effective use of information declared or obtained from the Tax Amnesty Returns and Statements of Total Assets or Statements of Assets, Liabilities, and Net Worth, as the case may be, filed under this Act. All statements and returns filed under this Act shall be maintained and processed separately from other records of the BIR, in accordance with the IRR. If the data requirements consist of information found in the income tax return of taxpayers, compliance with Section 71 of the National Internal Revenue Code of 1997, as amended, shall be

1 observed. The Information Management System shall likewise comply 2 with the provisions of Republic Act No. 10173, otherwise known as the 3 "Data Privacy Act of 2012" and such other laws relating to 4 confidentiality of information.

SEC. 14. Unlawful Divulgence of Tax Amnesty Return and

6 Supporting Documents. - It shall be unlawful for any person having knowledge of the Tax Amnesty Return and supporting documents, to 8 disclose any information relative thereto. Any violation hereof shall be penalized with a fine of not less than 11 One Hundred Fifty Thousand Pesos (PHP 150,000.00) and imprisonment of not less than six (6) years but not more than ten (10) years: Provided, That if the offender is an officer or employee of the BIR or any government entity, the penalties under Section 270 of the National Internal Revenue Code of 1997, as amended, shall apply: Provided, further, That the offender shall, in addition, suffer the penalty of perpetual disqualification to hold public office.

SEC. 15. Report to Oversight Committee. - The Commissioner

of Internal Revenue shall submit to the Oversight Committee referred to in Section 290 of the National Internal Revenue Code of 1997, as amended, through the Chairpersons of the Committee on Ways and Means of the Senate of the Philippines and the House of Representatives, a comprehensive report on the implementation of this Act within six (6) months after the one (1)-year period of availment of 26 the General Tax Amnesty.

SEC. 16. Implementing Rules and Regulations. - Within ninety

(90) days from the effectivity of this Act, the Secretary of Finance, in coordination with the Commissioner of Internal Revenue, shall promulgate the necessary rules and regulations for the effective implementation of this Act.

SEC. 17. Separability Clause. - Should any provision or part of

35 this Act be declared unconstitutional or invalid, the other provisions

1 and parts hereof, insofar as they are separable from the invalid ones, 2 shall remain in full force and effect.

SEC. 18. Repealing Clause. - All laws, rules and regulations, and

5 other issuances or parts thereof, which are inconsistent with the 6 provisions of this Act, are hereby repealed, amended, or modified accordingly.

SEC. 19. Effectivity. - This Act shall take effect fifteen (15) days

10 after its publication in the Official Gazette or in at least two (2) 11 newspapers of general circulation. Approved,