The Department of Finance (DOF), together with the Department of the Interior and Local Government (DILG) and the Department of Trade and Industry (DTI), issued Joint Memorandum Circular (JMC) No. 01-2026, or the Guidelines on the Imposition of Local Taxes, Fees, and Charges on Registered Business Enterprises (RBEs) Availing of Tax Incentives Under Republic Act No. 12066, to clarify and standardize the application of local taxes on RBEs nationwide.
The JMC, which took effect on March 30, 2026, addresses ambiguities arising from varying interpretations and implementation of the CREATE and CREATE MORE Acts, particularly with respect to transitioning RBEs. It provides businesses, local government units (LGUs), and investment promotion agencies (IPAs) with a clearer and more uniform framework for local tax administration to promote ease of doing business, encourage compliance and strengthen investor confidence.
The JMC clarifies that the Registered Business Enterprise Local Tax (RBELT) applies to RBEs availing of Income Tax Holiday (ITH) or Enhanced Deductions Regime (EDR) in economic zones, including expansion areas, under the CREATE MORE Act. It also provides that IPAs may enter into a Memorandum of Agreement (MOA) with LGUs to facilitate the collection, sharing, and remittance of RBELT.
In addition, the JMC provides that the RBELT, which shall not exceed two percent (2%) of the gross income of the RBE’s registered project or activity, shall be in lieu of all local taxes, fees, and charges, including local business taxes and real property taxes. Once an LGU imposes the RBELT through an ordinance, it may no longer separately impose taxes outside the RBELT framework.
The guidelines further clarify that when an IPA owns the land but grants beneficial use to an RBE, the RBE shall be considered the taxable person and may be liable for real property taxes and other applicable local taxes, including the RBELT.
To support implementation, the Fiscal Incentives Review Board (FIRB) Secretariat conducted nationwide town hall meetings on May 5, 12, and 14, 2026, to brief stakeholders on the application of the RBELT.
“Our goal is to translate policy into practice—ensuring that reforms are delivered, translated, and felt by our investors. The CREATE MORE Act was designed to make the Philippines a more competitive and investment-friendly destination. Our responsibility now is to ensure that its provisions are implemented clearly, consistently, and effectively. Through clear guidance and coordinated implementation, we are making compliance easier, providing greater predictability, and encouraging more investments into the country,” FIRB Chairperson and Finance Secretary Frederick D. Go said.
