REVENUE MEMORANDUM CIRCULAR NO. 55-2025 issued on June 10, 2025 clarifies Section 24 of Republic Act (R.A.) No. 12214, titled “An Act Amending Section 22, 24, 25, 27, 28, 32, 34, 38, 39, 42, 51, 52, 56, 57, 127, 149, 174, 176, 179, 190, 199, and 258 of Republic Act No. 8424, Otherwise Known as the National Internal Revenue Code of 1997, as Amended, and for Other Purposes”.

Pursuant to Section 24 of RA No. 12214 [Capital Markets Efficiency Promotion Act (CMEPA)], Section 258 of the National Internal Revenue Code of 1997, as amended (Tax Code), is further amended.

Based on the amendment, any person who carries on any business without registering the same with the Bureau of Internal Revenue in accordance with Section 236 of the Tax Code shall, upon conviction for each act or omission, be punished by a fine of not less than ₱ 5,000 but not more than ₱ 20,000, and imprisonment of not less than six (6) months but not more than two (2) years.

In the case of a person engaged in the business of distilling. rectifying, repacking, compounding, or manufacturing any article subject to Excise Tax, the penalty shall be a fine of not less than ₱ 30,000 but not more than ₱ 50,000, and imprisonment of not less than two (2) years but not more than four (4) years.

The recent amendment not only clarifies but firmly reinforces that the crime of Unlawful Pursuit of Business and its penalty under Section 258 of the Tax Code applies to failure to register a business, not to the non-payment of the ₱ 500.00 annual registration fee, which has already been repealed under RA No. 11976 (Ease of Paying Taxes Act).