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REVENUE REGULATIONS 19-2025 issued on August 5, 2025 implements the Documentary Stamp Tax (DST) rate adjustments and amendments to the documents and papers not subject to DST under Republic Act No. 12214 (Capital Markets Efficiency Promotion Act or CMEPA).

The Regulations shall cover documents, loan agreements, instruments, papers, acceptances, assignments, sales and transfers of the obligation, right or property incident thereto in respect of the transactions made or accomplished on July I, 2025 onwards.

Section 174 of the Tax Code, as amended by Section 19 of the CMEPA, now reads as follows:

SEC. 174. Stamp Tax on Original Issue of Shares of Stock – On every original issue, whether on organization, reorganization or for any lawful purpose, of shares of stock by any association, company, or corporation, there shall be collected a documentary stamp tax of SEVENTY-FIVE PERCENT OF ONE PERCENT (75% OF 1%) of the par value of such shares of stock: Provided, That in the case of the original issue of shares of stock without par value, the amount of the documentary stamp tax herein prescribed shall be based upon the actual consideration for the issuance of such shares of stock: Provided, further That in the case of stock dividends, on the actual value represented by each share.” (Emphasis supplied)

Section 176 of the Tax Code, as amended by Section 20 of the CMEPA, now reads as follows

“SEC. 176. Stamp Tax on Bonds, Debentures, and Certificates of Stock or Indebtedness Issued in Foreign Countries. – A documentary stamp tax of SEVENTY-FIVE PERCENT OF ONE PERCENT (75% OF 1%) of the value of the transactions shall be collected from the person selling or transferring bonds, debentures, certificates of stock, or certificates of indebtedness issued by any foreign country.” (Emphasis supplie

Section 179 of the Tax Code, as amended by Section 21 of the CMEPA, now reads as follows:

In cases where a loan agreement and a promissory note, mortgage, security interest over personal property and other contracts issued to secure such loan are simultaneously issued and executed, only one DST shall be imposed on either loan agreement or promissory note, mortgage, security interest over personal property and other contracts issued to secure such loan, whichever will yield a higher tax. Moreover, where only one instrument was prepared, made, signed or executed to cover a loan agreement/promissory note/pledge/mortgage, the DST prescribed in Section 195 of the Tax Code, on Stamp Tax on Mortgages, Pledges and Deeds of Trust, shall be paid and computed on the full amount of the loan or credit granted. In this regard, the instrument shall be treated as covering only one taxable transaction.

Section 199 of the Tax Code, as amended by Section 23 of the CMEPA, now reads as follows:

“SEC. 199. Documents and Papers Not Subject to Stamp Tax. – The provisions of Section 173 to the contrary notwithstanding, the following instruments, documents, and papers shall be exempt from the documentary stamp tax:

                                                  xxx

(e) Sale, exchange, redemption, or other disposition of shares of stock listed and traded through a local or foreign stock exchange.

                                                  xxx

(o) Original issuance, redemption, or other disposition of shares in a mutual fund company.

(p) Issuance of certificate or other evidence of participation in a mutual fund or unit investment trust fund.” (Emphasis supplied)