REVENUE MEMORANDUM CIRCULAR NO. 6-2015 issued on January 22, 2015 publishes the full text of Executive Order No. 173 entitled “Reduction and Condonation of Real Property Taxes and Interest/Penalties Assessed on the Power Generation Facilities of Independent Power Producers under Build-Operate-Transfer Contracts with Government-Owned and/or –Controlled Corporations”.
     All liabilities for real property tax on property, machinery and equipment (including any special levies accruing to the Special Education Fund) actually and directly used by Independent Power Producers (IPPs) for the production of electricity under Build-Operate-Transfer contracts (whether denominated Power Purchase Agreements, Energy Conversion Agreements or other contractual agreements) with GOCCs, assessed by LGUs and other entities authorized to impose real property tax, for all years up to 2014, are reduced to an amount equivalent to the tax due if computed based on an assessment level of 15% of the fair market value of said property, machinery and equipment depreciated at the rate of 2% per annum, less any amounts already paid by the IPPs. All fines, penalties and interest on such deficiency real property tax liabilities are also condoned and the concerned IPPs are relieved from payment thereof.