REVENUE MEMORANDUM CIRCULAR NO. 105-2025 issued on November 12, 2025 clarifies the taxability of Health Emergency Allowance (HEA) granted under Republic Act (RA) No. 11712 (Public Health Emergency Benefits and Allowances for Health Care Workers Act).

The HEA shall be released in full if a health worker or non-health care worker physically renders services for at least ninety-six (96) hours in a month; otherwise, the benefit shall be prorated.

As to its taxability, the HEA shall be treated as part of the “other benefits” pursuant to Section 32 (B) (7) (e) of the National Internal Revenue Code of 1997, as amended (Tax Code), which provides gross benefits received by officials and employees of public and private entities not exceeding Ninety Thousand Pesos (P 90,000.00) are exempt from Income Tax.

Accordingly, the grant of HEA to covered public and private healthcare workers or nonhealthcare workers, pursuant to an employer-employee relationship, regardless of employment status, may be excluded from the gross income and is not subject to Income Tax. Provided, that it falls within the threshold of P 90,000.00 under Section 32 (B) (7) (e) of the Tax Code.

However, for individuals engaged under contracts of service and job orders, there exists no employer-employee relationship between the hiring agency and hired healthcare workers or non-healthcare workers. In such a case, the covered public or private healthcare workers or non-healthcare workers are considered to be selfemployed professionals or independent contractors. Thus, the HEA shall be subject to Income Tax and other applicable taxes in accordance with the provisions of the Tax Code, and to the registration and compliance requirements under Revenue Memorandum Circular No. 51-2018.