REVENUE MEMORANDUM CIRCULAR NO. 36-2004 issued on June 16, 2004 circularizes the Supreme Court’s decision that pawnshops are not subject to the 5% lending investor’s tax under Section 116 of the National Internal Revenue Code of 1977, as amended.

           In view of the said decision, all assessments on pawnshops for percentage taxes as lending investors are hereby cancelled. For purposes of the gross receipt tax provided for under Republic Act No. 9294, the pawnshops are now subject thereof.