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REPUBLIC ACT NO. 8424 TAX REFORM ACT OF 1997 AN ACT AMENDING THE NATIONAL INTERNAL REVENUE CODE, AS AMENDED, AND FOR OTHER PURPOSES Be it enacted by the Senate and House of Representatives of the Philippines in Congress assembled: SECTION 1. Short Title - This Act shall be cited as the "Tax Reform Act of 1997". SECTION 2. State Policy. – It is hereby declared the policy of the State to promote sustainable economic growth through the rationalization of the Philippine internal revenue tax system, including tax administration; to provide, as much as possible, an equitable relief to a greater number of taxpayers in order to improve levels of disposable income and increase economic activity; and to create a robust environment for business to enable firms to compete better in the regional as well as the global market, at the same time that the State ensures that Government is able to provide for the needs of those under its jurisdiction and care. SECTION 3. Presidential Decree No. 1158, as amended by, among others, Presidential Decree No. 1994 and Executive Order No. 273, otherwise known as the National Internal Revenue Code, is hereby further amended. TITLE I ORGANIZATION AND FUNCTION OF THE BUREAU OF INTERNAL REVENUE SECTION 1. Title of the Code. - This Code shall be known as the National Internal Revenue Code of 1997. SEC. 2. Powers and duties of the Bureau of Internal Revenue. - The Bureau of Internal Revenue shall be under the supervision and control of the Department of Finance and its powers and duties shall comprehend the assessment and collection of all national internal revenue taxes, fees, and charges, and the enforcement of all forfeitures, penalties, and fines connected therewith, including the execution of judgments in all cases decided in its favor by the Court of Tax Appeals and the ordinary courts. The Bureau shall give effect to and administer the supervisory and police powers conferred to it by this Code or other laws. SEC. 3. Chief Officials of the Bureau of Internal Revenue. - The Bureau of Internal Revenue shall have a chief to be known as Commissioner of Internal Revenue, hereinafter referred to as the Commissioner and four (4) assistant chiefs to be known as Deputy Commissioners. SEC. 4. Power of the Commissioner to Interpret Tax Laws and to Decide Tax Cases. - The power to interpret the provisions of this Code and other tax laws shall be under the exclusive and original jurisdiction of the Commissioner, subject to review by the Secretary of Finance.

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REPUBLIC ACT NO. 8424TAX REFORM ACT OF 1997AN ACT AMENDING THE NATIONAL INTERNAL REVENUECODE, AS AMENDED, AND FOR OTHER PURPOSESBe it enacted by the Senate and House of Representatives ofthe Philippines in Congress assembled:SECTION 1. Sho! T"!#$ - This Act shall be cited as the Ta!Reform Act of "##$%SECTION 2. S!%!$ Po#"&'. & 't is hereby declared the policyof the State to promote sustainable economic gro(th throughthe rationali)ation of the Philippine internal revenue ta!system* including ta! administration+ to provide* as much aspossible* an e,uitable relief to a greater number of ta!payersin order to improve levels of disposable income and increaseeconomicactivity+ andtocreatearobust environment forbusiness to enable -rms to compete better in the regional as(ellas the globalmar.et* at the same time that the Stateensures that /overnment is able to provide for the needs ofthose under its 0urisdiction and care%SECTION (. P$)"*$+!"%# D$&$$ No. 11,8* as amendedby* among others* Presidential 1ecree 2o% "##3 and4!ecutive5rder2o% 6$7* other(ise.no(nasthe2ational'nternal Revenue Code* is hereby further amended%TITLE I ORGANI-ATION AND FUNCTION OF THE BUREAUOF INTERNAL REVENUESECTION 1. T"!#$ o. !h$ Co*$. - This Code shall be .no(nas the 2ational 'nternal Revenue Code of "##$%SEC.2.Po/$)%+**0!"$)o.!h$B0$%0o.I+!$+%#R$1$+0$. -The Bureau of 'nternal Revenue shallbe underthe supervision and control of the 1epartment of 8inance andits po(ers and duties shall comprehend the assessment andcollectionof all national internal revenueta!es* fees* andcharges* andtheenforcement of all forfeitures* penalties*and-nesconnectedthere(ith* includingthee!ecutionof0udgments in all cases decided in its favor by the Court of Ta!Appeals and the ordinary courts% The Bureau shall give e9ectto and administer the supervisory and police po(ersconferred to it by this Code or other la(s%SEC. (. Ch"$. O2&"%#) o. !h$ B0$%0 o. I+!$+%#R$1$+0$. - TheBureauof 'nternal Revenueshall haveachief tobe.no(nas Commissioner of 'nternal Revenue*hereinafter referredtoas theCommissioner andfour :3;assistant chiefs to be .no(n as 1eputy Commissioners%SEC. 4. Po/$o.!h$Co33"))"o+$!oI+!$4$!T%5L%/) %+* !o D$&"*$ T%5 C%)$). - The po(er to interpretthe provisions of this Code and other ta! la(s shall be underthee!clusiveandoriginal 0urisdictionoftheCommissioner*sub0ect to revie( by the Secretary of 8inance%The po(er to decide disputed assessments* refunds ofinternal revenue ta!es* fees or other charges* penaltiesimposedinrelationthereto* orothermattersarisingunderthis Code or other la(s or portions thereof administered bythe Bureau of 'nternal Revenue is vested in theCommissioner* sub0ect to the e!clusive appellate 0urisdictionof the Court of Ta! Appeals%SEC. ,. Po/$ o. !h$ Co33"))"o+$ !o O6!%"+I+.o3%!"o+, %+* !o S033o+, E5%3"+$, %+* T%7$T$)!"3o+' o. P$)o+). - 'n ascertaining the correctness ofany return* or in ma.ing a return (hen none has been made*or in determining the liability of any person for any internalrevenue ta!* or in collecting any such liability* or inevaluating ta! compliance* the Commissioner is authori)ed::A; To e!amine any boo.* paper* record* or other data (hichmay be relevant or material to such in,uiry+:B; To 5btain on a regular basis from any person other thanthe person (hose internal revenue ta! liability is sub0ect toaudit or investigation* or fromanyo0$). - The Commissioner* the1eputy Commissioners* the Revenue Regional 1irectors* theRevenue 1istrict 5hen to 8ile% - 5n or before the date of commencement ofemployment(ithanemployer* theemployeeshall furnishthe employer (ith a signed (ithholding e!emption certi-caterelating to the personal and additional e!emptions to (hichhe is entitled%:b; Changeof Status% - 'ncaseof changeof statusof anemployeeasaresult of (hichhe(ouldbeentitledtoalesser or greater amount of e!emption* the employee shall*(ithin ten :"B; days from such change* -le (ith the employera ne( (ithholding e!emption certi-cate re?ecting thechange%:c; Ise of Certi-cates% - The certi-cates -led hereunder shallbe used by the employer in the determination of the amountof ta!es to be (ithheld%:d; 8ailureto8urnishCerti-cate% - >hereanemployee* inviolationof this Chapter* either fails or refuses to-lea(ithholding e!emption certi-cate* the employer shall(ithholdtheta!esprescribedunder theschedulefor )eroe!emption of the (ithholding ta! table determined pursuantto Subsection :A; hereof%CED ?"!hho#*"+; o+ B%)") o. A1$%;$ ?%;$)% - TheCommissioner may* under rules and regulations promulgatedby the Secretary of 8inance* authori)e employers to::"; estimate the (ages (hich (ill be paid to an employee inany ,uarter of the calendar year+:6; determine the amount to be deducted and (ithheld uponeach payment of (ages to such employee during such,uarter as if the appropriate average of the (ages soestimated constituted the actual (ages paid+ and:7; deduct and (ithhold upon any payment of (ages to suchemployee during +such ,uarter such amount as may bere,uiredtobedeductedand(ithheldduringsuch,uarter(ithout regard to this Subsection%CFD H0)6%+* %+* ?".$% - >hen a husband and (ife eacharerecipients of (ages* (hether fromthesameor fromdi9erent employers* ta!es to be (ithheld shall be determinedon the follo(ing bases::"; The husband shall be deemed the head of the family andproper claimant of the additional e!emption in respect to anydependentchildren* unlesshee!plicitly(aiveshisrightinfavor of his (ife in the (ithholding e!emption certi-cate%:6; Ta!esshall be(ithheldfromthe(agesof the(ifeinaccordance (ith the schedule for )ero e!emption of the(ithholding ta! table prescribed in Subsection :1;:6;:d;hereof%CGD No+$)"*$+! A#"$+)% - >ages paid to nonresident alienindividualsengagedintradeorbusinessinthePhilippinesshall be sub0ect to the provisions of this Chapter%CHDE$%:$+* A*@0)!3$+!% -5norbeforetheendof thecalendar year but prior to the payment of the compensationfor the last payroll period* the employer shall determine theta! due fromeach employee on ta!able compensationincome for the entire ta!able year in accordance (ith Section63:A;% The di9erence bet(een the ta! due from theemployee for the entire year and the sum of ta!es (ithheldfrom Danuary to 2ovember shall either be (ithheld from hissalary in 1ecember of the current calendar year or refundedto the employee not later than Danuary 6C of the succeedingyear%SEC. 8=. L"%6"#"!' .o T%5% -CAD E34#o'$% - The employer shall be liable for the(ithholdingandremittanceof thecorrect amount of ta!re,uired to be deducted and (ithheld under this Chapter% 'fthe employer fails to (ithhold and remit the correct amountof ta! as re,uired to be (ithheld under the provision of thisChapter* such ta! shall be collected fromthe employertogether (ith the penalties or additions to the ta! other(iseapplicable in respect to such failure to (ithhold and remit%CBD E34#o'$$% - >here an employee fails or refuses to -lethe (ithholding e!emption certi-cate or (illfully suppliesfalse or inaccurate information thereunder* the ta! other(isere,uiredtobe(ithheldbytheemployershall becollectedfrom him including penalties or additions to the ta! from theduedateof remittanceuntil thedateof payment% 5ntheother hand* e!cess ta!es (ithheld made by the employer dueto::"; failure or refusal to -le the (ithholding e!emptioncerti-cate+ or:6; false and inaccurate information shall not be refunded tothe employee but shall be forfeited in favor of the/overnment%SEC. 81. F"#"+; o. R$!0+ %+* P%'3$+! o. T%5$)?"!hh$#*% - 4!cept as the Commissioner other(ise permits*ta!es deducted and (ithheld by the employer on (ages ofemployees shall becoveredby a returnandpaidtoanauthori)ed agent ban.+ Collection Agent* or the dulyauthori)edTreasurer of thecityor municipality(heretheemployer has his legal residence or principal place ofbusiness* or in case the employer is a corporation* (here theprincipal ohere theproperty referred to consists of t(o or more items* theaggregate value of such items shall be used for the purposeof computing the deduction%:7; Transfers for Public Ise% - The amount of all the be,uests*legacies* devises or transfers to or for the use of the/overnment of the Republic of the Philippines* or any politicalsubdivision thereof* for e!clusively public purposes%:3; The 8amily Home% - An amount e,uivalent to the currentfairmar.etvalueofthedecedentKsfamilyhome:Provided*ho(ever* That if the said current fair mar.et value e!ceeds5ne million pesos :P"*BBB*BBB;* the e!cess shallbe sub0ectto estate ta!% As a sine ,ua non condition for the e!emptionor deduction* said family home must have been thedecedentKs family home as certi-ed by the barangay captainof the locality%:C; Standard 1eduction% - An amount e,uivalent to 5nemillion pesos :P"*BBB*BBB;%:=; Hedical 4!penses% - Hedical 4!pensesincurredbythedecedent (ithin one :"; year prior to his death (hich shall bedulysubstantiated(ithreceipts: Provided* Thatinnocaseshall the deductible medical e!penses e!ceed 8ive HundredThousand Pesos :PCBB*BBB;%:$; Amount Received by Heirs Inder Republic Act 2o% 3#"$% -Any amount received by the heirs fromthe decedent -employeeasaconse,uenceofthedeathofthedecedent-employee in accordance (ith Republic Act 2o% 3#"$:Provided* That such amount is included in the gross estate ofthe decedent%CBD D$*0&!"o+) A##o/$* !o No+$)"*$+! E)!%!$)% - 'n thecaseof anonresident not aciti)enof thePhilippines* bydeductingfromthevalueof that part of hisgrossestate(hich at the time of his death is situated in the Philippines::"; 4!penses* Gosses* 'ndebtedness and Ta!es% - Thatproportionof thedeductionsspeci-edinparagraph:"; ofSubsection :A; of this Section (hich the value of such partbears to the value of his entire gross estate (hereversituated+:6; Property Previously Ta!ed% - An amount e,ual to the valuespeci-edbelo(of anypropertyformingpart of thegrossestatesituatedinthePhilippinesof anyperson(hodied(ithin -ve :C; years prior to the death of the decedent* ortransferred to the decedent by gift (ithin -ve :C; years priorto his death* (here such property can be identi-ed as havingbeenreceivedbythedecedent fromthedonor bygift* orfrom such prior decedent by gift* be,uest* devise orinheritance* or (hich can be identi-ed as having beenac,uired in e!change for property so received:5ne hundred percent :"BBJ; of the value if the priordecedent died (ithin one :"; year prior to the death of thedecedent* or if the property (as transferred to him by gift*(ithin the same period prior to his death+4ighty percent :EBJ; of the value* if the prior decedent diedmore than one :"; year but not more than t(o :6; years priorto the death of the decedent* or if the property (astransferred to him by gift (ithin the same period prior to hisdeath+Si!ty percent :=BJ; of the value* if the prior decedent diedmore than t(o :6; years but not more than three :7; yearspriortothedeathof thedecedent* orif theproperty(astransferred to him by gift (ithin the same period prior to hisdeath+8orty percent :3BJ; of the value* if the prior decedent diedmore than three :7; years but not more than four :3; yearspriortothedeathof thedecedent* orif theproperty(astransferred to him by gift (ithin the same period prior to hisdeath+ andT(enty percent :6BJ; of the value* if the prior decedent diedmorethanfour:3;yearsbutnotmorethan-ve:C;yearspriortothedeathof thedecedent* orif theproperty(astransferred to him by gift (ithin the same period prior to hisdeath%These deductions shall be allo(ed only (here a donorKs ta!*or estate ta! imposedunder thisTitle is -nallydeterminedand paid by or on behalf of such donor* or the estate of suchprior decedent* as the case may be* and only in the amount-nally determined as the value of such property indetermining the value of the gift* or the gross estate of suchprior decedent* and only to the e!tent that the value of suchpropertyis includedinthat part of thedecedentKs grossestate(hichat thetimeof his deathis situatedinthePhilippines+ and only if* in determining the value of the netestate of the prior decedent* no deduction is allo(able underparagraph :6; of Subsection :B; of this Section* in respect ofthe property or properties given in e!change therefore%>here a deduction (as allo(ed of any mortgage or other lienin determining the donorKs ta!* or the estate ta! of the priordecedent* (hich(aspaidin(holeor inpart prior tothedecedentKsdeath* thenthedeductionallo(ableundersaidparagraphshall bereducedbytheamount sopaid% Suchdeductionallo(ableshall bereducedbyanamount (hichbears the same ratio to the amounts allo(ed as deductionsunder paragraphs :"; and :7; of this Subsection as theamountother(isedeductibleunderparagraph:6;bearstothe value of that part of the decedentKs gross estate (hich atthe time of his death is situated in the Philippines% >here thepropertyreferredtoconsistsoft(o:6;ormoreitems* theaggregate value of such items shall be used for the purposeof computing the deduction%:7; TransfersforPublicIse% - Theamountof all be,uests*legacies* devises or transfers to or for the use of the/overnment of the Republic of the Philippines or any politicalsubdivision thereof* for e!clusively public purposes%CCD Sh%$ "+ !h$ Co+@0;%# Po4$!'% - the net share of thesurviving spouse in the con0ugal partnership property asdiminishedbytheobligationsproperlychargeabletosuchproperty shall* for the purpose of this Section* be deductedfrom the net estate of the decedent%CDD M")&$##%+$o0) Po1")"o+)% - 2o deduction shall beallo(edinthecaseof anonresident not aciti)enof thePhilippines* unless the e!ecutor* administrator* or anyone ofthe heirs* as the case may be* includes in the return re,uiredto be -led under Section #B the value at the time of his deathof that part of the gross estate of the nonresident notsituated in the Philippines%CED T%5 C$*"! .o E)!%!$ T%5$) 4%"* !o % Fo$";+Co0+!'% -:"; 'n /eneral% - The ta! imposedby this Title shall becredited (ith the amounts of any estate ta! imposed by theauthority of a foreign country%:6;GimitationsonCredit% -Theamountofthecreditta.enunder this Section shallbe sub0ect to each of the follo(inglimitations::a; The amount of the credit in respect to the ta! paid to anycountryshall not e!ceedthesameproportionof theta!against (hich such credit is ta.en* (hich the decedentKs netestate situated (ithin such country ta!able under this Titlebears to his entir net estate+ and:b; The total amount of the credit shall not e!ceed the sameproportionof theta!against (hichsuchcredit is ta.en*(hich the decedentKs net estate situated outside thePhilippinesta!ableunder thisTitlebearstohisentirenetestate%SEC. 87 E5$34!"o+ o. C$!%"+ A&90")"!"o+) %+*T%+)3"))"o+)% - The follo(ing shall not be ta!ed::A; The merger of usufruct in the o(ner of the na.ed title+:B; The transmission or delivery of the inheritance or legacyby the -duciary heir or legatee to the -deicommissary+:C; The transmission from the -rst heir* legatee or donee infavor of another bene-ciary* in accordance (ith the desire ofthe predecessor+ and:1; All be,uests* devises* legacies or transfers to social(elfare* cultural and charitable institutions* no part of the netincomeof (hichinsures tothebene-t of anyindividual:Provided* ho(ever* That not more than thirty percent :7BJ;of the said be,uests* devises* legacies or transfers shall beused by such institutions for administration purposes%SEC. 88. D$!$3"+%!"o+ o. !h$ V%#0$ o. !h$ E)!%!$. :CAD U)0.0&!% - To determine the value of the right ofusufruct* use or habitation* as (ell as that of annuity* thereshall be ta.en into account the probable life of thebene-ciary in accordance (ith the latest Basic StandardHortality Table* to be approved by the Secretary of 8inance*upon recommendation of the 'nsurance Commissioner%CBDPo4$!"$)% - Theestateshall beappraisedatitsfairmar.et value as of the time of death% Ho(ever* the appraisedvalueof real property as of thetimeof deathshall be*(hichever is higher of -:"; The fair mar.et value as determined by theCommissioner* or:6; The fair mar.et value as sho(n in the schedule of values-!ed by the Provincial and City Assessors%SEC. 89.No!"&$o.D$%!h!o6$F"#$*% - 'nall casesoftransfers sub0ect to ta!* or (here* though e!empt from ta!*the gross value of the estate e!ceeds T(enty thousand pesos:P6B*BBB;* thee!ecutor* administrator or anyof thelegalheirs* as the case may be* (ithin t(o :6; months after thedecedentKs death* or (ithin a li.e period after ,ualifying assuche!ecutor or administrator* shall givea(rittennoticethereof to the Commissioner% SEC. 9=. E)!%!$ T%5 R$!0+). :CAD R$90"$3$+!)% - 'n all cases of transfers sub0ect to theta! imposed herein* or (here* though e!empt from ta!* thegross valueof theestatee!ceeds T(ohundredthousandpesos:P6BB*BBB;* or regardlessof thegrossvalueof theestate* (here the said estate consists of registered orregistrablepropertysuchas real property* motor vehicle*shares of stoc. or other similar property for (hich aclearance from the Bureau of 'nternal Revenue is re,uired asa condition precedent for the transfer of o(nership thereof inthe name of the transferee* the e!ecutor* or theadministrator* or any of the legal heirs* as the case may be*shall -le a return under oath in duplicate* setting forth::"; The value of the gross estate of the decedent at the timeof his death* or in case of a nonresident* not a citi)en of thePhilippines* of thatpartof hisgrossestatesituatedinthePhilippines+:6; The deductions allo(ed from gross estate in determiningthe estate as de-ned in Section E=+ and:7; Suchpart of suchinformationasmayat thetimebeascertainable and such supplemental data as may benecessary to establish the correct ta!es%Provided* ho(ever* That estate ta! returns sho(ing a grossvalue e!ceeding T(o million pesos :P6*BBB*BBB; shall besupported(ithastatementdulycerti-edtobyaCerti-edPublic Accountant containing the follo(ing::a; 'temi)ed assets of the decedent (ith their correspondinggrossvalueat thetimeof hisdeath* or inthecaseof anonresident* not a citi)en of the Philippines* of that part of hisgross estate situated in the Philippines+:b; 'temi)ed deductions from gross estate allo(ed in SectionE=+ and:c; Theamount of ta!due(hether paidor still dueandoutstanding%CBDT"3$.ohere the ta!es are assessed by reason of negligence*intentional disregard of rules and regulations* or fraud on thepart of theta!payer* noe!tension(ill begrantedbytheCommissioner%'f an e!tension is granted* the Commissioner may re,uire thee!ecutor* oradministrator* orbene-ciary* asthecasemaybe* to furnish a bond in such amount* not e!ceeding doublethe amount of the ta! and (ith such sureties as theCommissioner deems necessary* conditioned upon thepayment of the said ta! in accordance (ith the terms of thee!tension%CCD L"%6"#"!'.o P%'3$+! - Theestateta! imposedbySectionE3shall bepaidbythee!ecutor or administratorbefore delivery to any bene-ciary of his distributive share ofthe estate% Such bene-ciary shall to the e!tent of hisdistributive share of the estate* be subsidiarily liable for thepayment of such portion of the estate ta! as his distributiveshare bears to the value of the total net estate%8or the purpose of this Chapter* the termKe!ecutorK orKadministratorK meansthee!ecutor or administrator of thedecedent* or if there is no e!ecutor or administratorappointed* ,uali-ed* and acting (ithin the Philippines* thenany person in actual or constructive possession of anyproperty of the decedent%SEC. 92. D")&h%;$ o. E5$&0!o o A*3"+")!%!o .o3P$)o+%# L"%6"#"!'. - 'f the e!ecutor or administrator ma.esa (ritten application to the Commissioner for determinationof the amount of the estate ta! and discharge from personalliabilitytherefore* theCommissioner :assoonaspossible*and in any event (ithin one :"; year after the ma.ing of suchapplication* or if the application is made before the return is-led* then (ithin one :"; year after the return is -led* but notafter the e!piration of the period prescribed for theassessment of theta!inSection6B7shall not notifythee!ecutor or administrator of theamount of theta!% Thee!ecutororadministrator* uponpaymentoftheamountof(hich he is noti-ed* shall be discharged frompersonalliability for any de-ciency in the ta! thereafter found to bedue and shall be entitled to a receipt or (riting sho(ing suchdischarge%SEC. 9(. D$hen the amount secured does not e!ceed 8ive thousandpesos :PC*BBB;* T(enty pesos :P6B%BB;%:b; 5n each 8ive thousand pesos :PC*BBB;* or fractional partthereof in e!cess of 8ive thousand pesos :PC*BBB;* anadditional ta! of Ten pesos :P"B%BB;%5n any mortgage* pledge* or deed of trust* (here the sameshall be made as a security for the payment of a ?uctuatingaccount or future advances (ithout -!ed limit* thedocumentary stamp ta! on such mortgage* pledge or deed oftrust shall becomputedontheamount actuallyloanedorgiven at the time of the e!ecution of the mortgage* pledge ordeedof trust* additional documentarystampta!shall bepaid(hichshall becomputedonthebasisof theamountadvanced or loaned attheratesspeci-ed above: Provided*ho(ever* That if the full amount of the loan or credit* grantedunder the mortgage* pledge or deed of trust shall becomputed on the amount actually loaned or given at the timeofthee!ecutionofthemortgage* pledgeordeedoftrust%Ho(ever* if subse,uent advances are made on suchmortgage* pledgeordeedoftrust* additional documentarystamp ta! shall be paid (hich shall be computed on the basisof theamount advancedor loanedat theratesspeci-edabove: Provided* ho(ever* That if the full amount of the loanor credit* grantedunder themortgage* pledgeor deedoftrust is speci-ed in such mortgage* pledge or deed of trust*the documentary stamp ta! prescribed in this Section shallbe paid and computed on the full amount of the loan or creditgranted%SEC. 198. S!%34 !%5 o+ D$$*) o. S%#$ %+*Co+1$'%+&$) o. R$%# Po4$!'. : 5n all conveyances*deeds* instruments* or (ritings* other than grants* patents ororiginal certi-cates of ad0udication issued by the/overnment* (herebyanyland* tenement* or other realtysold shall be granted* assigned* transferred or other(iseconveyedtothepurchaser* orpurchasers* ortoanyotherperson or persons designated by such purchaser orpurchasers* thereshall becollectedadocumentarystampta!* at the rates herein belo(prescribed* based on theconsideration contracted to be paid for such realty or on itsfair mar.et value determined in accordance (ith Section =:4;of this Code* (hichever is higher: Provided* That (hen one ofthecontractingparties is the/overnment theta!hereinimposed shall be based on the actual consideration%:a; >hen the consideration* or value received or contractedto be paid for such realty after ma.ing proper allo(ance ofany encumbrance* does not e!ceed5nethousandpesos:P"*BBB; -fteen pesos :P"C%BB;%:b; 8or each additional 5ne thousand Pesos :P"*BBB;* orfractional part thereof in e!cess of 5ne thousand pesos:P"*BBB; of such consideration or value* 8ifteen pesos:P"C%BB;%>hen it appears that the amount of the documentary stampta!payablehereunder has beenreducedbyanincorrectstatement of theconsiderationinany conveyance* deed*instrument or (riting sub0ect to such ta! the Commissioner*provincial or cityTreasurer* or other revenueohenanyindividual (hohas paidtheannualregistration fee dies* and the same business is continued bythe person or persons interested in his estate* no additionalpayment shall be re,uired for the residue of the term (hichtheta!(as paid: Provided* ho(ever* That thepersonorpersonsinterestedintheestateshould* (ithinthirty:7B;days from the death of the decedent* submit to the Bureau of'nternal Revenueor theregional or revenue1istrict 5here the facts subse,uently gathered by the Bureau of'nternal Revenuearemateriallydi9erentfromthefactson(hich the ruling is based+ or:c; >here the ta!payer acted in bad faith%TITLE X STATUTORE OFFENSES AND PENALTIESCHAPTER I : ADDITIONS TO THE TAXSEC. 247. G$+$%# Po1")"o+). ::a; The additions to theta!orde-ciency ta! prescribed inthis Chapter shall apply to all ta!es* fees and chargesimposed in this Code% The Amount so added to the ta! shallbe collected at the same time* in the same manner and aspart of the ta!%:b; 'f the (ithholding agent is the /overnment or any of itsagencies* political subdivisions or instrumentalities* or agovernment-o(nedorcontrolledcorporation* theemployeethereof responsible for the (ithholding and remittance of theta!shall bepersonallyliablefor theadditionstotheta!prescribed herein%:c;theterm B4$)o+B*asusedinthisChapter* includesanoaysandHeans of the Senate and House Representatives and four :3;additional membersfromeachhouse* tobedesignatedbythe Spea.er of the House of Representatives and the SenatePresident* respectively%The Committee shall* among others* in aid of legislation::"; Honitor and ensure the proper implementation ofRepublic Act 2o% E63B+:6; 1etermine that the po(er of the Commissioner tocompromise and abate is reasonably e!ercised+:7; Revie(the collection performance of the Bureau of'nternal Revenue+ and:3; Revie( the implementation of the programs of the Bureauof 'nternal Revenue%'n furtherance of the hereinabove cited ob0ectives* theCommittee is empo(ered to re,uire of the Bureau of 'nternalRevenue* submissionof all pertinentinformation* includingbut not limitedto: industryaudits+ collectionperformancedata+ status report on criminal actions initiated againstpersons+ and submission of ta!payer returns: Provided*ho(ever* That any return or return information (hich can beassociated (ith* or other(ise identify* directly or indirectly* aparticular ta!payer shall befurnishedtheCommitteeonly(hen sitting in 4!ecutive Session unless such ta!payerother(ise consents in (riting to such disclosure%TITLE XIII REPEALING PROVISIONSSEC. 291. I+ G$+$%#. - All la(s* decrees* e!ecutive orders*rules and regulations or parts thereof (hich are contrary toor inconsistent (ith this Code are hereby repealed* amendedor modi-ed accordingly%TITLE XIV FINAL PROVISIONSSEC. 292. S$4%%6"#"!' C#%0)$. - 'f any clause* sentence*paragraphor part of thisCodeshall bead0udgedbyanyCourt of competent 0urisdiction to be invalid* such 0udgmentshall nota9ect* impair orinvalidatetheremainderof saidCode* butshall becon-nedinitsoperationtotheclause*sentence* paragraph or part thereof directly involved in thecontroversy%