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Investor guide · RA 12066

CREATE MORE Law: a foreign investor's guide to Philippine tax incentives (RA 12066)

Income tax holidays, a 5% special rate or enhanced deductions, and VAT and duty relief for registered Philippine business enterprises, explained for a foreign investor. Every figure carries a badge showing how well we could verify it.

· Independent summary, not legal or tax advice

Estimate your savings Read the summary

Skyline of high-rise office and residential towers in Bonifacio Global City, Metro Manila, seen over tree cover
Makati / Bonifacio Global City skyline — Photo: Lawrence Ruiz, CC BY-SA 4.0, via Wikimedia Commons

In short

The summary

  • Up to 27 yrs Maximum incentive period: FIRB bracket: 7 ITH + 20 post-ITH; bonus years can add more. Verified[1]
  • 5% SCIT rate for exporters: Of gross income, in lieu of national and local taxes. Verified[1]
  • 0% VAT on local purchases by exporters: Registered export enterprises. Verified[1, 3]
  • 20 working days IPA decision time: One extension of up to 20 days. Verified[1]
  • US$7.79B FDI net inflows 2025: BSP; a five-year low. Verified[19]
  • PHP 260.9B PEZA approvals 2025: 314 projects. Verified[21]

Badges: Verified Per seminar deck Unverified Our analysis Approximate

Who should apply

Exporters

At least 70% of output exported. Can take the 5% SCIT on gross income after the income tax holiday, plus 0% VAT on local purchases and duty-free project imports.

Verified[1, 3]

Domestic-market builders

Serving the Philippine market. Income tax holiday first, then the enhanced deduction regime (EDR) at 20% on taxable income after enhanced deductions. SCIT is not available.

Verified[1]

Relocating out of Metro Manila

Three bonus ITH years for fully relocating out of NCR, plus two in conflict or disaster areas, subject to the ITH cap. Regional locations also start from a longer base holiday.

Verified[1] Unverified

Persona groupings are our reading of the statute, not an official classification.

Process

How it works in four steps

  1. Check the SIPP

    Your activity must be on the Strategic Investment Priority Plan. Projects not listed are automatically disapproved, and the plan is valid for three years.

    Verified[16, 17]

  2. Get approved by the right body

    Capital up to PHP 15B goes to the investment promotion agency (PEZA, BOI and others). Above that, the Fiscal Incentives Review Board decides. The agency has 20 working days, extendable once by up to 20 more.

    Verified[1]

  3. Register

    Register the project as a business enterprise with the agency. Registration fixes the tier, location bracket and incentive period that apply to you.

    Our analysis

  4. Avail and report

    Claim the incentives in your returns and file the annual reports. For taxable years ending 31 Dec 2026 onward, a notarized summary report is mandatory.

    Verified[6, 8]

Approval brackets

Who approves you, and for how long

Capital invested decides the approving body and the post-holiday window.

Approval brackets
BracketCapitalITHThenTotalStatus
Investment promotion agency (PEZA, BOI, etc.)Decision within 20 working days, one extension of up to 20 more (Sec. 297-A).Up to and including PHP 15 billion4-710 years SCIT or EDR (export) / 10 years EDR (domestic)14-17 yearsVerified[1, 3]
Fiscal Incentives Review Board (FIRB)Same ITH years as the IPA bracket, then 20 post-ITH years (Sec. 296-A).Above PHP 15 billion4-720 years SCIT/EDR (export) / 20 years EDR (domestic and high-value DME)24-27 yearsVerified[1]
President (Sec. 301)Details of the Certificate of Entitlement mechanism were not verified.At least PHP 50 billion or at least 10,000 direct local jobs within 3 yearsNegotiatedExtensions only for projects with at least 10,000 direct local employees, capped at 5 years (Sec. 296) or 10 years (Sec. 296-A)Beyond the FIRB scheduleVerified[1]
High-value domestic market enterprise (DME)Definition in Sec. 293(J).Capital above PHP 15 billion, or export sales of at least US$100 million in the prior year4-7EDR only; 0% VAT on local purchases and import exemptionAs per approving bracketVerified[1, 3]

The incentives

What you actually get

Income tax holiday (years), by tier and location Verified[1, 15]

Income tax holiday years by SIPP tier and location
SIPP tierNCRMetro / contiguousAll other areas
Tier I4 yrs5 yrs6 yrs
Tier II5 yrs6 yrs7 yrs
Tier III6 yrs7 yrs7 yrs

Bonus: +3 years for fully relocating out of NCR, +2 in conflict or disaster areas, capped at 8 years. Unverified[1, 15] +3 / +2 bonus years are in the statute (Sec. 296). The 8-year ITH cap and 40-year total cap come from one secondary source (ASEAN Briefing) and were not found in the statute extraction.

SCIT versus EDR

SCIT versus EDR
Feature5% SCITEDRStatus
Who can use itExport enterprises only (at least 70% of annual output exported)Export enterprises and domestic market enterprisesVerified[1, 3]
Tax basis5% of gross income earned20% of taxable income after enhanced deductionsVerified[1, 2]
ReplacesAll national and local taxesRegular 25% CIT only; a local tax of up to 2% of gross income (RBELT) can still applyVerified[1]
DeductionsNone (gross-income based)Eight enhanced deductions, including 100% additional on powerVerified[1, 6]
SwitchingChoice is irrevocable; cannot be combined with EDRCannot be granted at the same time as SCIT. A domestic market enterprise may elect EDR from the start of commercial operationsVerified[3]
ComplianceStandard registration reportingSubstantiation plus a Notarized Comprehensive Summary Report from taxable years ending 31 Dec 2026; related-party deductions disallowed unless arm's lengthVerified[6, 8]
MCITNot applicableMCIT applies if it exceeds the regular tax computed after enhanced deductions (rate not verified)Unverified[6]

Enhanced deductions (EDR) Unverified

Enhanced deductions
DeductionExtraNoteStatus
Additional depreciation: buildings10%10% additional allowance. Rests on secondary sources; verify against Sec. 294(C).Unverified[6, 9]
Additional depreciation: machinery and equipment20%20% additional allowance. Rests on secondary sources; verify against Sec. 294(C).Unverified[6, 9]
Research and development (local spend, approved proposal)100%100% additional deduction. Secondary sources only.Unverified[6, 9]
Training (IPA-approved, direct Filipino employees)100%100% additional deduction. Secondary sources only.Unverified[6, 9]
Power expense (actual electricity cost, registered operations)100%100% additional deduction, i.e. 200% in total; raised from 50% under CREATE. Confirmed in statute and DOF Order 026-2026.Verified[1, 6]
Labor expense (direct local employees in registered activity)50%50% additional deduction. Secondary sources only.Unverified[6, 9]
Domestic input expense (needs at least 50% value-addition)50%50% additional deduction; notarized summary required. Secondary sources only.Unverified[6, 9]
Reinvestment allowance (manufacturing, tourism)50%Up to 50% of the amount reinvested within 5 years; availment ends 31 Dec 2034. The calculator drops this deduction for calendar years after 2034.Verified[1, 6]
Trade fairs and missions (IPA-approved export promotion)50%50% additional deduction. Not modelled in the calculator.Verified[1, 6]
Enhanced NOLCO0%Losses of the first 3 years of operations may be carried over for 5 years after the ITH ends. Not modelled.Verified[1, 6]

VAT, duties and other taxes

VAT, duties and other taxes
ItemTreatmentStatus
Imports directly attributable to the registered projectImport VAT and duty exemption (Sec. 294(D)-(E)); PEZA MC 2025-052 lists goods deemed directly attributableVerified[1, 11]
Local purchases by registered export enterprises0% VAT regardless of locationVerified[1, 3]
Local purchases by high-value DMEs0% VAT and import exemptionVerified[3]
Sales to ordinary DMEs12% VAT unless otherwise exemptVerified[1]
Resale of VAT-exempt imported assets0% if the buyer is an export enterprise; 12% on net book value if the seller is a DME and the buyer is not. Disposal needs IPA approval in the first 5 years; unapproved disposal triggers solidary liability for twice the exemption (Sec. 295(C))Verified[1]
VAT refundsCommissioner to grant or deny within 90 days of complete documents (Sec. 112(C)); reconsideration 15 days; CTA appeal within 30 days. BIR guidance cited: RR 10-2025 and RMC 32-2025Verified[1, 12]
Zero-rating certificationIssued by the IPA, subject to BIR post-auditVerified[12, 11]
Registered Business Enterprise Local Tax (RBELT)Not more than 2% of gross income for RBEs in ITH or EDR; not imposed under SCIT (Sec. 294(F))Verified[1]
Dividends and branch profitsSources conflict: 25% final on dividends to non-resident foreign corporations, reducible to 15% under tax-sparing or treaty; 15% branch profit remittance tax with possible exemption for registered activities. Not resolvedUnverified[10]

Local taxes. A registered business enterprise pays local business tax capped at 2% of gross income (RBE local tax), and under SCIT the 5% replaces national and local taxes. Verified[1, 5, 2]

Live calculator

Estimate your tax savings

Illustrative arithmetic on your own assumptions. It compares the regular 25% tax with the incentive path year by year. It is not tax advice and does not model every rule.

Worked example Our analysis

Worked example: Tier I, all other areas, export enterprise, SCIT. Gross income ₱300M, net income ₱150M, investment ₱5B, 16 years.

Worked example
PhaseYearsRegular tax per yearIncentive tax per yearSaved over phase
Income tax holiday6₱37.5M₱0₱225M
5% SCIT10₱37.5M₱15M₱225M
Total16₱600M total₱150M total₱450M (75%)

Illustrative arithmetic at 25% CIT on PHP 150M net income for 16 years (PHP 600M) versus 5% of PHP 300M gross income for the 10 SCIT years (PHP 150M); ITH years pay nothing. Turn on JavaScript to change the assumptions.

Your project
Accepts 300M or 1.5B.
Approval route: IPA
SIPP tier of your activity
Check your activity code in the current SIPP. See Sectors.
Enterprise type
Post-holiday regime
Enhanced deductions per year (EDR only)
Counts 10% of the amount as an extra deduction.
Counts 20% of the amount as an extra deduction.
Counts 100% of the amount as an extra deduction.
Counts 100% of the amount as an extra deduction.
Counts 100% of the amount as an extra deduction.
Counts 50% of the amount as an extra deduction.
Counts 50% of the amount as an extra deduction.
Counts 50% of the amount as an extra deduction.
Rates and assumptions
Illustrative exchange rate, not a quote.

Results

—

— lower than the regular tax over — years

Regular tax
—
With incentives
—
Present value of savings
—
Effective rate
—
Income tax holiday
—
Then (SCIT)
—

Cumulative tax: regular versus incentive path

Year-by-year schedule

Year by year tax schedule
YearPhaseRegular taxWith incentivesSavingCumulative saving

Reinvestment allowance only counts for years up to 2034. Illustrative arithmetic, not tax advice. Our analysis

Which activities qualify

Sectors and SIPP tiers

Two different things are shown separately. 'Official 2026 SIPP' is the 2026 Strategic Investment Priority Plan (DTI/BOI Memorandum Order No. 47, s. 2026) as described by two published summaries that themselves differ; we did not read the order itself. 'Seminar deck examples' are the sector examples shown in the seminar slides and are NOT confirmed against the 2026 SIPP.

Official 2026 SIPP (MO 47, signed 21 May 2026, released 2 Jun 2026) Unverified[16, 17]

Tier I

Summary A: Agriculture, fishery and forestry; manufacturing; halal, kosher and organic activities; services; health care and disaster risk reduction; infrastructure, logistics and energy; waste, water and climate projects. [16]

Summary B: Agriculture, value-adding manufacturing, healthcare, IT-BPM, aircraft MRO, environmental infrastructure. [17]

Tier II

Summary A: Defense-related services, industrial value chain gaps, food security. [16]

Summary B: IC design, oil refining, critical minerals processing, EV components and infrastructure, renewable energy, energy-efficient vessels and aircraft, defense services. [17]

Tier III

Summary A: Science, technology and innovation. [16]

Summary B: R&D, patent commercialization, AI and data science, quantum, aerospace, cybersecurity, biotech, startup ecosystems. [17]

Also covered: export activities, special-law activities, area-specific priorities. Tourism is registered through TIEZA (34 projects worth PHP 14.5B registered under CREATE and CREATE MORE since 2021). The SIPP is valid for 3 years subject to review; projects not listed are automatically disapproved (Sec. 300). Verified

Examples from the seminar deck (not confirmed against the 2026 SIPP) Per seminar deck

Tier I

  • Semiconductors and electronics
  • Pharmaceuticals
  • Processed food

Tier II

  • Desalination
  • Sustainable aviation

Tier III

  • Highly technical advanced manufacturing

These may reflect the 2022 SIPP (MO 61) or the 2024 amendment rather than MO 47. Check the activity code in the current SIPP before relying on a tier.

Sector context

  • Philippine AI+ Infrastructure Masterplan 2026-2033: US$34.4B needed, about 1.5 GW of data-center capacity targeted by 2033 Verified[38]
  • BOI approvals 2025: energy PHP 970.09B, mass housing PHP 241.65B, transport and storage PHP 230.06B Verified[22]
  • PEZA H1 2026: electronics led, then ecozone development, then IT-BPM Verified[23]
Technicians in cleanroom suits assembling precision equipment in a semiconductor-grade clean room
Illustrative, not a Philippine facility (non-Philippine stock image). Semiconductor / clean-room manufacturing (non-Philippine) — Photo: Aileen Devlin/Jefferson Lab from Newport News, USA, Public domain, via Wikimedia Commons
Rows of solar panels at a solar power plant in Bulacan with mountains in the background
Solar farm, Bulacan — Photo: FBenjr123, CC BY-SA 4.0, via Wikimedia Commons
Line of wind turbines along the coast of Bangui, Ilocos Norte, with mountains behind
Bangui Wind Farm, Ilocos Norte — Photo: Patrickroque01, CC BY-SA 4.0, via Wikimedia Commons

Where to locate

Locations and hot spots

Location sets your holiday length: NCR is shortest, the metro and contiguous list is in the middle, and everywhere else gets the longest.

NCR: 4 / 5 / 6 yrs (Tier I / II / III)Metro / contiguous: 5 / 6 / 7 yrs (Tier I / II / III)All other areas: 6 / 7 / 7 yrs (Tier I / II / III)

Hot-spot corridors

Skyline of high-rise office and residential towers in Bonifacio Global City, Metro Manila, seen over tree cover
Makati / Bonifacio Global City skyline — Photo: Lawrence Ruiz, CC BY-SA 4.0, via Wikimedia Commons

Metro Manila / NCR

NCR Verified

Subway partial operations are reported for 2027, 2028 or 2032 depending on the source (unverified). NSCR Valenzuela-Malolos phase targeted for late 2027 and the Clark extension for 2H 2028. Unverified[34]

Toll plaza of the CALAX expressway near Laguna Technopark in Laguna province
Laguna Technopark / CALAX — Photo: LMP 2001, CC BY-SA 4.0, via Wikimedia Commons

Calamba / Santa Rosa / Biñan / Cabuyao, Laguna

Metro / contiguous Unverified

The LGUs are named in the TIEZA list. PLDT's 11th data center, a PHP 5B build, is in Laguna. Verified[13]

Colorful main gate of the PEZA-run Cavite Economic Zone in Rosario, Cavite, with workers arriving by tricycle
Cavite Economic Zone, Rosario — Photo: Ralff Nestor Nacor, CC BY-SA 4.0, via Wikimedia Commons

Dasmariñas / Imus / Bacoor, Cavite

Metro / contiguous Unverified

Average Cavite lot prices reached about PHP 20,000/sqm (sale) at end-2025. CALAx status not found. Unverified[37]

Cainta / Antipolo / Taytay, Rizal

Metro / contiguous Unverified

BOI is assisting Singapore's SpaceDC on a US$700M data center in Cainta (Sept 2025). Verified[35]

Meycauayan / San Jose del Monte, Bulacan

Metro / contiguous Unverified

Named in the TIEZA list. NSCR phase 1 ends at Malolos, Bulacan. Verified[34]

Taal Volcano island in Taal Lake viewed from the Tagaytay ridge, with fish pens on the water
Taal Volcano from Tagaytay — Photo: LMP 2001, CC BY-SA 4.0, via Wikimedia Commons

Silang / Tagaytay uplands, Cavite

All other areas Unverified

No sourced facts found. Unverified

Cargo trucks and roll-on roll-off ferries at Batangas International Port
Batangas port — Photo: Ralff Nestor Nacor, CC BY-SA 4.0, via Wikimedia Commons

Batangas (port, LIMA, Lipa)

All other areas Our analysis

A Batangas ecozone development was among two new ecozone projects worth PHP 5.9B combined in H1 2026. LIMA specifics not found in this research. Verified[36]

Clark Freeport / New Clark City, Pampanga-Tarlac

All other areas Our analysis

BCDA reported PHP 49.96B in approved investments in H1 2026; investors named include Lufthansa Technik Philippines, FedEx and UPS, with an AI hub planned. A US$2.7B hyperscale campus is cited for New Clark City. Verified[33]

View over the Subic Bay Freeport Zone industrial area and bay in Zambales
Subic Bay Freeport Zone — Photo: Alankang, CC BY-SA 4.0, via Wikimedia Commons

Subic Bay Freeport, Zambales

All other areas Our analysis

The Luzon Economic Corridor links Subic, Clark, Manila and Batangas. No Subic-specific figure found. Verified[36]

Bataan (Mariveles, FAB)

All other areas Our analysis

No sourced facts found. Unverified

View over Cebu City with the Cebu Business Park and IT Park high-rises in the distance
Cebu IT Park / Cebu City skyline — Photo: Patrickroque01, CC BY-SA 4.0, via Wikimedia Commons

Metro Cebu: Cebu IT Park, Mactan (Lapu-Lapu)

Metro / contiguous Unverified

A US$200M nitrile glove project (South Luzon and Cebu, 2,000 jobs) and a Cebu export manufacturing venture are in PEZA's 2026 pipeline. Whether Mactan counts as metro is unclear. Verified[36]

Aerial view of Davao City rooftops and the Davao Gulf under a partly cloudy sky
Davao City skyline — Photo: Teemu Väisänen, CC BY-SA 4.0, via Wikimedia Commons

Metro Davao

Metro / contiguous Unverified

Named in the TIEZA list. No sourced investment facts found. Unverified[13]

Cagayan de Oro / Misamis (PHIVIDEC)

All other areas Our analysis

A Misamis Occidental ecozone was among the two new ecozones worth PHP 5.9B in H1 2026. PHIVIDEC specifics not found. Verified[36]

Iloilo

All other areas Our analysis

No sourced facts found. Unverified

City bracket list

Cities and their location bracket
CityProvinceBracketStatus
ManilaMetro Manila (NCR)NCRVerified
Quezon CityMetro Manila (NCR)NCRVerified
MakatiMetro Manila (NCR)NCRVerified
Taguig (incl. BGC)Metro Manila (NCR)NCRVerified
PasigMetro Manila (NCR)NCRVerified
MandaluyongMetro Manila (NCR)NCRVerified
San JuanMetro Manila (NCR)NCRVerified
MarikinaMetro Manila (NCR)NCRVerified
CaloocanMetro Manila (NCR)NCRVerified
MalabonMetro Manila (NCR)NCRVerified
NavotasMetro Manila (NCR)NCRVerified
ValenzuelaMetro Manila (NCR)NCRVerified
Las PiñasMetro Manila (NCR)NCRVerified
MuntinlupaMetro Manila (NCR)NCRVerified
ParañaqueMetro Manila (NCR)NCRVerified
PasayMetro Manila (NCR)NCRVerified
PaterosMetro Manila (NCR)NCRVerified
MeycauayanBulacanMetro / contiguousUnverified
San Jose del MonteBulacanMetro / contiguousUnverified
BacoorCaviteMetro / contiguousUnverified
DasmariñasCaviteMetro / contiguousUnverified
ImusCaviteMetro / contiguousUnverified
BiñanLagunaMetro / contiguousUnverified
CabuyaoLagunaMetro / contiguousUnverified
CalambaLagunaMetro / contiguousUnverified
Santa RosaLagunaMetro / contiguousUnverified
AntipoloRizalMetro / contiguousUnverified
CaintaRizalMetro / contiguousUnverified
TaytayRizalMetro / contiguousUnverified
San PedroLagunaMetro / contiguousUnverified
Metro Cebu (Cebu City, Mandaue, Lapu-Lapu, others)CebuMetro / contiguousUnverified
Metro DavaoDavao del SurMetro / contiguousUnverified
Lipa / Batangas CityBatangasAll other areasOur analysis
Clark / New Clark CityPampanga / TarlacAll other areasOur analysis
Subic Bay FreeportZambalesAll other areasOur analysis
MarivelesBataanAll other areasOur analysis
Silang / Tagaytay uplandsCaviteAll other areasUnverified
Cagayan de OroMisamis OrientalAll other areasOur analysis
Iloilo CityIloiloAll other areasOur analysis

The metro list comes from TIEZA and secondary sources, not the IRR text. See the discrepancies below.

By the numbers

Investment dashboard

Up to 27 yrsMaximum incentive periodFIRB bracket: 7 ITH + 20 post-ITH; bonus years can add moreVerified[1]
5%SCIT rate for exportersOf gross income, in lieu of national and local taxesVerified[1]
0%VAT on local purchases by exportersRegistered export enterprisesVerified[1, 3]
20 working daysIPA decision timeOne extension of up to 20 daysVerified[1]
US$7.79BFDI net inflows 2025BSP; a five-year lowVerified[19]
PHP 260.9BPEZA approvals 2025314 projectsVerified[21]
BSP foreign direct investment, net inflows (US$ billion) [18, 19]
Data table
YearUS$ bnNote
20238.925preliminary Verified
20249.398revised Verified
20257.791five-year low, above the BSP's US$7B projection Verified
PEZA approved investments (PHP billion) [20, 21]
Data table
YearPHP bnNote
2023175.709 Verified
2024214about; omitted from the chart Unverified
2025260.89314 projects, 78,741 jobs Verified

2024 is left off the chart because we could not verify it. H1 2026: PHP 140.69B against a 300B target. Verified[23]

Headline corporate income tax rate (%) in ASEAN [24]
Data table
CountryRateNote
Singapore17% Verified
Thailand20% Verified
Vietnam20%Top-up tax to a 15% minimum for large multinationals. Verified
Indonesia22%Single source. Verified
Malaysia24% Verified
Philippines25%Single-source for the ASEAN comparison; 25% regular rate confirmed in law summaries. Verified
Philippines, export enterprise under SCIT5% of gross5% of gross income, not comparable with a headline rate on profit. Verified

The 5% SCIT applies to gross income, so it is not directly comparable with the headline rates, which apply to profit.

Incentive years heatmap

Income tax holiday years Verified

NCRMetro / contiguousAll other areas
Tier I 4 yrs5 yrs6 yrs
Tier II 5 yrs6 yrs7 yrs
Tier III 6 yrs7 yrs7 yrs

Total years, IPA bracket (ITH + 10) Verified

NCRMetro / contiguousAll other areas
Tier I 14 yrs15 yrs16 yrs
Tier II 15 yrs16 yrs17 yrs
Tier III 16 yrs17 yrs17 yrs

Total years, FIRB bracket (ITH + 20) Verified

NCRMetro / contiguousAll other areas
Tier I 24 yrs25 yrs26 yrs
Tier II 25 yrs26 yrs27 yrs
Tier III 26 yrs27 yrs27 yrs

Before any relocation or conflict-area bonus years.

Who is investing

Source economies and investor profiles

BSP: main sources of 2025 equity placements

  • Japan
  • United States
  • Singapore
  • South Korea

Verified[19]

PSA Q4 2025 foreign approvals

  • Netherlands: PHP 33.05B
  • Japan: PHP 17.88B
  • Singapore: PHP 17.66B

Verified[27]

PEZA H1 2026 top sources

  • Netherlands
  • South Korea
  • Singapore
  • Indonesia
  • Germany
  • Japan

Verified[23]

US firms exploring IT and logistics in ecozones

  • United States

Verified[40]

  • Full-year 2025 country ranking is not available. Unverified
  • Full foreign ownership of telecom and data centers is now allowed (TechRepublic report). Verified[38]

Which incentives fit which profile

Investor profiles and relevant incentives
ProfileMost relevantStatus
Electronics and semiconductor5% SCIT, duty-free imports, ITHOur analysis
Data centersITH, VAT zero-rating, power-cost deductionOur analysis
Renewable energyBOI energy incentivesOur analysis
BPO / global business servicesSCIT or enhanced deductionsOur analysis
TourismTIEZA registrationOur analysis

The profile-to-incentive mapping is our analysis, not a published finding.

Key dates

Timeline

  1. CREATE Act (RA 11534) enacted Per seminar deck

    Taken from the seminar deck; not re-sourced.

  2. RA 12066 (CREATE MORE) signed Unverified[28, 29, 1]

    Conventus Law gives 11 Nov; PortCalls gives 8 Nov.

  3. Law takes effect Verified[30]

  4. FIRB interim IRR (Advisory 007-2024) Verified[31]

  5. Final IRR signed (effective 20 Feb 2025 on publication); FIRB Advisory 001-2025 Verified[32, 7]

  6. BIR RR 10-2025 on VAT (numbering conflicts across sources) Unverified[12]

  7. BIR RMC 42-2025 circularizes the IRR Verified[7]

  8. 2026 SIPP (MO 47) signed / released Verified[16]

  9. FIRB Advisory 010-2026 circularizes DOF Order 026-2026 (EDR terms) Verified[6]

  10. BIR RMC 105-2026 posted; notarized summary report mandatory for taxable years ending 31 Dec 2026 onward Verified[6, 8]

  11. Reinvestment allowance availment ends; pre-CREATE 5% GIT holders may keep it until this date Verified[1, 6]

Read before you rely on it

Risks and caveats

  • Incentives are discretionary and registration-specific. Your certificate, not this page, defines what you get.
  • SIPP tiers, the metro list and enhanced-deduction percentages change by issuance. Confirm each with the approving agency.
  • Reporting duties are real: missing the annual summary report can put incentives at risk.
  • Domestic-market projects cannot use the 5% SCIT.

These bullets are our general caution. Our analysis

Discrepancies and open questions

Where sources or the seminar deck disagree, or we could not confirm a point, we list it here instead of picking a side.

  1. 20% versus 25% corporate income tax Verified[1, 5]
    The deck's EDR example used 20%. That is the EDR rate for registered enterprises; the regular rate is 25%. A PHP 30M baseline at 20% becomes PHP 37.5M at 25%, and EDR tax is PHP 10M against it.
  2. SCIT is for export enterprises only Verified[1, 3]
    The deck glossary implies SCIT is generally available. Under the statute, domestic market enterprises get ITH plus EDR only, and the calculator forces EDR for them.
  3. Deck tier examples not confirmed against the 2026 SIPP Unverified[16, 17, 41]
    The deck's sector examples may reflect the 2022 SIPP (MO 61) or the 2024 amendment. Two summaries of the 2026 SIPP (MO 47) also differ from each other. Check the activity code in the order itself.
  4. Metro and contiguous area list Unverified[13]
    The list comes from the TIEZA FAQ and secondary sources, not the IRR text. San Pedro (Laguna) is on the TIEZA list but is missing from some working lists, and whether Mactan counts as Metro Cebu is unclear.
  5. Domestic market enterprise post-ITH period: 10 years or 5 Unverified[1, 3, 15, 4]
    The statute text and Forvis Mazars say 10 years of EDR after the ITH. ASEAN Briefing says 5 years. We follow the statute; one BDB summary also shows a '9-14 years' figure that looks like a mislabel.
  6. Signing date: 8 or 11 November 2024 Unverified[28, 29, 1]
    Sources conflict (Conventus Law: 11 Nov; PortCalls: 8 Nov; our statute extraction: 8 Nov).
  7. Enhanced deduction percentages Unverified[1, 6, 9]
    Power (100% additional), reinvestment (up to 50%) and trade fairs (50%) are confirmed in the statute. The 10%/20% depreciation, 100% R&D, 100% training, 50% labor and 50% domestic-input figures rest on secondary sources; verify against Sec. 294(C).
  8. ITH cap of 8 years and 40-year total Unverified[15]
    One secondary source states them; we did not find them in the statute extraction. The calculator applies the 8-year cap as an assumption.
  9. Dividend withholding tax and branch profit tax Unverified[10]
    Secondary descriptions conflict: 25% versus 15% on dividends, and whether registered-activity profits are exempt from the branch profit remittance tax. Not resolved; take tax advice.
  10. Infrastructure dates Unverified[34]
    Metro Manila Subway partial operations are reported as 2028, 2032, or Q4 2027 depending on the source. These dates are not verified, and land prices are omitted because no credible consultant publishes them for specific parks.

Questions

FAQ

What is the CREATE MORE Act?
RA 12066 amends Title XIII of the National Internal Revenue Code (the CREATE Act, RA 11534). It sets income tax holidays, a 5% special corporate income tax or enhanced deductions, VAT and duty relief for registered business enterprises whose activity is listed in the Strategic Investment Priority Plan.
How long can incentives last?
Up to 14 to 17 years for projects up to PHP 15 billion approved by an investment promotion agency (4 to 7 years of income tax holiday plus 10 years), and 24 to 27 years for projects above PHP 15 billion approved by the FIRB. Relocating fully out of NCR adds 3 years and conflict or disaster areas add 2, subject to the cap.
Is the 5% SCIT available to domestic-market companies?
No. SCIT is for export enterprises, meaning at least 70% of annual output is exported. Domestic market enterprises receive the income tax holiday and then the enhanced deduction regime (20% on taxable income after enhanced deductions).
Who approves the registration?
An investment promotion agency such as PEZA or BOI approves projects with capital of PHP 15 billion or less, within 20 working days with one extension of up to 20. The FIRB approves projects above PHP 15 billion. Projects must be listed in the SIPP or they are automatically disapproved.
Does location change the incentive?
Yes. The income tax holiday is shorter in NCR (4 to 6 years) than in metro or contiguous areas (5 to 7) or other areas (6 to 7). The list of metro and contiguous LGUs used here comes from the TIEZA FAQ and has not been checked against the IRR.
What is the difference between SCIT and EDR?
SCIT is 5% of gross income in place of national and local taxes. EDR is 20% of taxable income after enhanced deductions, such as 100% additional on power expense, with a local tax of up to 2% of gross income still possible. Only one can be chosen and the choice is irrevocable.
What new compliance applies from 2026?
Under DOF Order 026-2026, enterprises on the EDR must substantiate deductions and file a Notarized Comprehensive Summary Report with the IPA within 30 days after filing the income tax return, for taxable years ending 31 December 2026 onward. Related-party deductions are disallowed unless at arm's length.
Is this legal or tax advice?
No. This page is an independent summary built from the statute text and published commentary, some of it unverified, and its calculator is illustrative arithmetic. Confirm eligibility and rates with your IPA and a Philippine tax adviser before relying on any figure.

Sources

Sources, credits and disclaimer

Disclaimer. Independent summary, not legal or tax advice. Built from statute text and published commentary; items marked Unverified or Per seminar deck have not been confirmed against primary sources.

  1. RA 12066 statute text (Lawphil) accessed 20 Oct 2026
  2. Grant Thornton Philippines: The CREATE MORE Act (RA 12066) accessed 20 Oct 2026
  3. Forvis Mazars Philippines: CREATE MORE Act tax alert accessed 20 Oct 2026
  4. BDB Law: CREATE MORE summary (PDF) accessed 20 Oct 2026
  5. Batas Natin: resident foreign corporation tax, Sec. 28(A) under CREATE accessed 20 Oct 2026
  6. Grant Thornton: DOF Department Order 026-2026 (Enhanced Deduction Regime) accessed 20 Oct 2026
  7. KPMG Philippines: Special InTax, March 2025 accessed 20 Oct 2026
  8. KPMG Philippines: Special InTax, August 2026 accessed 20 Oct 2026
  9. NDV Law: enhanced deductions regime accessed 20 Oct 2026
  10. PwC Tax Summaries: Philippines withholding taxes accessed 20 Oct 2026
  11. PwC Philippines: But wait, there is more for exporters under CREATE MORE accessed 20 Oct 2026
  12. Philstar: Simplifying VAT refunds under CREATE MORE (6 May 2025) accessed 20 Oct 2026
  13. TIEZA FAQ: fiscal incentives for TIEZA-registered enterprises (metro/contiguous LGU list) accessed 20 Oct 2026
  14. DOE slide deck: Registration Procedure under the CREATE Law accessed 20 Oct 2026
  15. ASEAN Briefing: How location affects tax incentives in the Philippines (19 Aug 2026) accessed 20 Oct 2026
  16. Philstar: Marcos OKs 2026 investment promotion blueprint (3 Jun 2026) accessed 20 Oct 2026
  17. Ocampo & Suralvo: BOI approves the 2026 SIPP (30 Jul 2026) accessed 20 Oct 2026
  18. PIDS: FDI net inflows inch up 0.1% in 2024 accessed 20 Oct 2026
  19. Philstar: FDI inflows fall to five-year low (12 Mar 2026) accessed 20 Oct 2026
  20. Tribune: PEZA secures P19.5B approved investments (14 Dec 2023) accessed 20 Oct 2026
  21. Philstar: PEZA investment approvals hit P261 billion (25 Dec 2025) accessed 20 Oct 2026
  22. PortCalls: BOI-approved investments in 2025 reach P1.56T accessed 20 Oct 2026
  23. PortCalls: PEZA approved investments almost double to P140B in H1 2026 accessed 20 Oct 2026
  24. Grant Thornton Vietnam: ASEAN Tax Guide 2026 (PDF) accessed 20 Oct 2026
  25. Trading Economics: Singapore corporate tax rate accessed 20 Oct 2026
  26. TaxAtlas: Vietnam corporate tax accessed 20 Oct 2026
  27. Tribune: Approved foreign investments hit P10.3B in Q4 2025 accessed 20 Oct 2026
  28. Conventus Law: RA 12066 signed 11 Nov 2024 accessed 20 Oct 2026
  29. PortCalls: CREATE MORE IRR signed (cites 8 Nov 2024 signing) accessed 20 Oct 2026
  30. Grant Thornton: BIR suspends audits from 16 Dec 2024 (cites 27 Nov 2024 effectivity) accessed 20 Oct 2026
  31. SunStar: Interim IRR on availment of incentives accessed 20 Oct 2026
  32. Baker McKenzie: DOF and DTI jointly issue the CREATE MORE IRR accessed 20 Oct 2026
  33. Context.ph: BCDA sees P100B investment surge in 2026 accessed 20 Oct 2026
  34. Context.ph: NSCR timeline accessed 20 Oct 2026
  35. Malaya: BOI sees multi-billion peso data center investments accessed 20 Oct 2026
  36. Philstar: Ecozone investments nearly double in H1 2026 (30 Jun 2026) accessed 20 Oct 2026
  37. Inquirer Plus: Cavite lot prices accessed 20 Oct 2026
  38. TechRepublic: Philippines AI infrastructure timeline and data centers accessed 20 Oct 2026
  39. Context.ph: TIEZA sees tourism investment surge in Q4 accessed 20 Oct 2026
  40. Philstar: US firms exploring IT, logistics investments in ecozones accessed 20 Oct 2026
  41. Supreme Court E-Library: 2022 SIPP (MO 61) accessed 20 Oct 2026
  42. Context.ph: Skyway-NLEX Connector 2027 accessed 20 Oct 2026
  43. Philippine Statistics Authority (via PortCalls): PSA approved foreign investments 2025 accessed 20 Oct 2026

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