Author MRTC

REVENUE REGULATIONS NO. 6-2024

Issued on April 11, 2024 to implement Section 45 of Republic Act (RA) No. 11976, also known as the Ease of Paying Taxes (EOPT) Act. The regulations focus on reducing interest and penalty rates specifically for micro and small taxpayers as classified under Section 21 (B) of the Tax Code, as amended by the EOPT Act, which provides:

  1. “Micro Taxpayer” – shall refer to a taxpayer whose gross sales for a taxable year is less than Three Million Pesos (₱3,000,000.00).
  2. “Small Taxpayer” – shall refer to a taxpayer whose gross sales for a taxable year is Three Million Pesos (₱3,000,000.00) to less than Twenty Million Pesos (₱20,000,000.00).

The RR No. 6-2024 imposes a penalty of ten percent (10%) of the amount due in the following cases:

  1. Failure to file a tax return and pay the tax by the prescribed due date, with exceptions for timely filed initial returns that are later amended. Additionally, if a tax deficiency is discovered during an audit due to a late-filed return, a penalty will be imposed.
  2. Failure to pay the deficiency tax within the specified time frame stated in the notice of assessment.
  3. Failure to pay the full or partial amount of tax shown on any required return by the prescribed payment date.

Further, the said RR imposes penalties on the following:

  1. A penalty of fifty percent (50%) of the tax or deficiency tax is imposed for willful neglect to file a return or for false or fraudulent filing of a return.
  2. Substantial under-declaration of taxable sales or income exceeding thirty percent (30%) or substantial overstatement of deductions exceeding thirty percent (30%) constitutes prima facie evidence of a false or fraudulent return.
  3. Interest at a reduced rate of fifty percent (50%) of the mandated interest rate, with the current legal interest rate set at 6%, is applied on any unpaid tax amount.
  4. A penalty of ₱500.00 is imposed for failure to file information returns, statements, lists, keep records, or supply required information, with an annual aggregate limit of ₱12,500.00.
  5. A reduced compromise penalty rate of fifty percent (50%) is applied for certain criminal violations not involving fraud, as specified under Annex “A” of Revenue Memorandum Order No. 7-2015.

For this purpose, compromise penalties are collected in lieu of criminal prosecution based on a valid compromise agreement between the taxpayer and the Commissioner of Internal Revenue (CIR).
Provided that, the compromise penalty amount specified in the regulations may differ only with approval from the CIR or his authorized representatives.

Provided, further, that compromise offer lower than the prescribed amount may be accepted after approval by the CIR or his authorized representatives.

Finally, the regulations clarify that they apply prospectively, in accordance with Section 51 of RA No. 11976.