The Bureau of Internal Revenue (BIR), through Revenue Memorandum Circular (RMC) No. 75-2026, issued a comprehensive Frequently Asked Questions (FAQ) guide governing One- Time Transactions (ONETT). The said Circular consolidates existing revenue regulations, memorandum circulars, and administrative issuances into a single reference designed to simplify the processing of One Time Transaction Computation Sheets (OCS) and issuance of Electronic Certificate Authorizing Registration (eCARs).
With the enactment of RA No. 11976 or the Ease of Paying Taxes (EOPT) Act, the filing of any tax return shall now be made electronically. Manual filing is permitted only when the BIR’s electronic systems are unavailable. For payment of tax due, the same may at the option of the taxpayer be done manually or electronically. For Electronic Filing and Payment System (eFPS) taxpayers, the same still paid using the said system unless the BIR Form required is not yet available in the eFPS.
The Circular also clarifies that while taxes may be filed and paid through any Authorized Agent Bank, jurisdiction over the processing of the Electronic Certificate Authorizing Registration (eCAR) remains with the appropriate Revenue District Office (RDO) based on the nature of the transaction.
Although tax returns and tax payments may now be filed in any Authorized Agent Bank, jurisdiction for processing the eCAR remains unchanged.
The appropriate RDO depends upon the nature of the transaction:
- Sale of real property – RDO having jurisdiction over the location of the property.
- Sale or transfer of unlisted shares of stock – RDO where the seller is registered or resides.
- Donation – RDO where the donor is registered or resides.
- Estate proceedings – RDO having jurisdiction over the estate’s TIN or, in certain cases, the decedent’s business registration.
The Circular therefore distinguishes between the convenience of filing and the authority to process applications, preserving territorial jurisdiction over ONETT transactions. Moreover, the Circular reinforces the requirement that taxpayers submit the original or certified true copies of required documents.
The original transfer instrument, such as the Deed of Absolute Sale, will be stamped with details of the issued eCAR before being returned to the taxpayer. To ensure accountability, taxpayers are likewise furnished with an acknowledged Checklist of Documentary Requirements (CDR) as proof that complete documentary requirements have been submitted.
Conversely, applications supported by incomplete documentation shall not be accepted. Instead, the taxpayer will receive a CDR identifying the missing requirements necessary for processing. This procedure strengthens due process while minimizing uncertainty regarding documentary compliance. Also, the Circular incorporates the processing timelines prescribed under the BIR Citizen’s Charter 2024.
The prescribed processing periods are:
| Transaction | OCS | eCAR |
| Simple transfer of real property or shares | 3 working days | 7 working days |
| Complex transactions | 7 working days | 7 working days |
| Estate tax transactions | 20 working days | 7 working days |
The reckoning period begins only after the submission of complete documentary requirements together with proof of payment of applicable taxes and fees. The classification of “simple,” “complex,” and “highly technical” transactions is likewise clarified, thereby providing taxpayers with more realistic expectations regarding processing time. Further, the Circular specifies whose TINs are required in ONETT transactions.
The Circular likewise explains the proper RDO where non-registered parties may secure a TIN for ONETT purposes. Where a person other than the taxpayer personally transacts with the BIR, the Circular requires documentary proof of authority which minimizes fraudulent transactions while preserving administrative efficiency.
Also, several provisions of the Circular specifically address estate taxation. Unlike in the old rule, estate tax returns may now be filed regardless of whether the decedent’s business has already been closed with the BIR. Estate tax processing is no longer conditioned on the prior cancellation of the decedent’s Taxpayer Identification Number (TIN), while the estate is instead required to secure its own separate TIN for tax administration purposes. In addition, taxpayers are no longer required to submit Certificates of Property Holdings as part of the documentary requirements for estate tax filing, reducing the administrative burden on heirs and estate administrators.
The Circular likewise explains the requirements for claiming the Family Home Deduction, emphasizing proof of residence and ownership while clarifying that the family home’s address need not exactly match the address appearing in the death certificate. It further explained, among others that:
- only the decedent’s share is deductible if the property is conjugal or inherited;
- condominium parking slots may be included as part of the Family Home if titled in the decedent’s name; and
- the deduction may still be claimed even if the estate is processed in the RDO having jurisdiction over the decedent’s business rather than over the Family Home, provided the required barangay certification and other conditions are satisfied.
Further, the Circular clarifies the treatment of Certificates Authorizing Registration (CARs) and electronic Certificates Authorizing Registration (eCARs). Manual CARs not yet presented to the Register of Deeds are no longer valid and must be replaced with eCARs. Conversely, eCARs previously issued through the BIR’s electronic system remain valid and no longer require revalidation. In case of loss, an eCAR may be reprinted upon compliance with the prescribed documentary requirements and payment of the applicable fees and documentary stamp tax.
As defined under Section 39 (A) (1) of the National Revenue Code of 1997, as amended (Tax Code), the Circular reiterates the statutory definition of capital assets while identifying properties that are automatically treated as ordinary assets, including inventory, property held primarily for sale, depreciable business assets, and real property used in trade or business.
It likewise confirms that properties acquired by banks through foreclosure and real properties owned by real estate lessors and held for lease are both treated as ordinary assets; and the property’s classification in the tax declaration generally controls in determining the applicable zonal value, even if the property’s actual use or the predominant use of surrounding properties differs. These clarifications help reduce uncertainty in determining whether a transfer is subject to capital gains tax or creditable withholding tax.
On how taxes should be computed and paid in installment transactions, the Circular provided a clearer guidance:
For sales of ordinary assets, it distinguishes between buyers who are engaged in business and those who are not. Where the buyer is not engaged in trade or business, creditable withholding tax (CWT) may generally be remitted upon payment of the last installment, provided the accumulated withholding is sufficient to cover the tax due. Where the buyer is engaged in business, however, CWT must be withheld and remitted with every installment based on the proportion of collections to the total contract price.
Documentary stamp tax (DST) on installment sales covered by a Contract to Sell accrues upon execution of the Deed of Absolute Sale, with the tax base determined using the higher of the selling price or the applicable fair market value at the time the Contract to Sell is executed.
For sales of unlisted shares of stock, the Circular also confirms that an eCAR may be issued on an installment basis, provided the agreement specifically identifies the shares covered by each installment, the payment schedule, and the shares attributable to each payment.
The Circular likewise provides a consolidated explanation of the tax treatment of foreclosure sales. It clarifies the triggering events for payment of capital gains tax, creditable withholding tax, and documentary stamp tax, depending on whether the foreclosure is judicial or extrajudicial and whether the mortgagee is a bank.
It also explains how the redemption period affects the due dates for these taxes, providing practical guidance on transactions that have historically generated uncertainty.
Finally, the Circular specifies the correct tax forms to be used whenever additional tax payments become necessary after approval of the ONETT Computation Sheet. Separate forms are prescribed depending on whether the deficiency involves Capital Gains Tax; Creditable Withholding Tax; Donor’s Tax; Estate Tax; or Documentary Stamp Tax.
Where the deficiency assessment arises after the issuance of the eCAR, BIR Form No. 0605 becomes the proper payment form.
Conclusion
RMC No. 75-2026 represents a significant administrative reform in the BIR’s management of One-Time Transactions. Rather than introducing entirely new tax rules, the Circular consolidates dispersed regulations into a coherent procedural framework that enhances consistency, transparency, and predictability.
Among its most notable contributions are the mandatory shift toward electronic filing under the Ease of Paying Taxes Act, the standardization of jurisdictional rules for eCAR processing, the clarification of documentary and valuation requirements, and the establishment of definitive processing timelines under the BIR Citizen’s Charter. The Circular also provides long-needed guidance on recurring issues involving installment sales, capital versus ordinary asset classification, estate tax administration, reissuance of eCARs, and the treatment of foreclosures and family home deductions.
For lawyers, accountants, real estate practitioners, estate administrators, and taxpayers, the Circular serves as a comprehensive procedural guide that reduces uncertainty in ONETT transactions. By streamlining compliance while maintaining safeguards against tax evasion and documentary fraud, RMC No. 75-2026 advances the objectives of efficient tax administration and facilitates the timely transfer of property rights, reinforcing the government’s commitment to modernizing the Philippine tax system.
This guide provides a general overview of the above transactions at the time of writing only and is not intended to be a comprehensive legal advice. This should also not be taken as an opinion on the topic. For more details and information, you may coordinate with any GVES Law Partner regarding the matter.
Atty. Beryl Joyce B. Barba is an Associate at GVES Law.