New Year’s Wish: Legislation of a taxpayer’s bill of rights

By: Atty. Euney Marie J. Mata-Perez on January 8, 2026

HAPPY New Year, everyone!

The new year is the best time to take stock, look back and count our blessings, as well as a time to look forward and make resolutions (and wishes). We can do the same concerning the taxation regime of our country.

In 2025, we saw the passage of Republic Act (RA) 12214, the Capital Markets Efficiency Promotion Act, as well as RA 12253, the Enhanced Fiscal Regime for Large-Scale Metallic Mining Act. Both laws seek to boost our capital markets and our mining industry.

Two other key issuances became effective in 2025: the value-added tax (VAT) on Digital Services Act (RA 12023), which expanded the 12-percent value-added tax to include digital services and put in the tax ambit nonresident digital service providers such as online marketplaces, cloud services and online advertisers, and the Create More Act (RA 12066), which became effective in early 2025, further refining the corporate tax incentive framework, clarifying the scope of VAT zero-rating for suppliers to registered enterprises and mandating a national e-invoicing system.

What is our wish list then with regard to the tax legislative agenda for 2026? My main wish is the passage of a taxpayer’s bill of rights, which is pending in the Senate and the House of Representatives.

House Bills 956 and 3207 were filed in 2025 to ordain a comprehensive bill of rights for taxpayers to enhance protection and build public trust. They also propose the creation of an Office of the National Taxpayer Advocate under the Department of Finance to assist taxpayers with problems, monitor administrative practices and recommend reforms to the Bureau of Internal Revenue and the Bureau of Customs.

At the Senate, meanwhile, are Senate Bill (SB) 844, the Taxpayer’s Bill of Rights and Obligations Act (filed by Sen. Jinggoy Estrada on Aug. 4, 2025), and SB 621 (filed by Sen. Sherwin Gatchalian on July 15, 2025), which similarly propose a taxpayer’s bill of rights. Both are pending before the Senate ways and means and finance committees.

A taxpayer’s bill of rights seeks to make taxpayer’s experience in dealing with revenue to be fair, transparent and easy so as to elicit greater taxpayer’s trust and confidence in the government, thereby improving their willingness to comply with their tax obligations and consequently increase government revenue collections.

In the Philippines, it is a known fact that taxpayer compliance is often hindered by the complexity of tax rules, lack of accessible information and the perception or experience of arbitrary enforcement by tax authorities, including repeated audits done without a sensible audit program and risk profiling of taxpayers. These challenges are compounded by weak enforcement mechanisms and limited revenues for redress, as well as corruption.

It has been reported by the Organization for Economic Cooperation and Development (OECD) that the Philippines’ tax to gross domestic product (GDP) ratio was 17.8 percent in 2023, lower than the Asia-Pacific average (19.5 percent) and significantly below the OECD average (33.9 percent). The key economic indicator shows a country’s total tax revenue as a percentage of GDP, reflecting its fiscal health and ability to fund public services. The low ratio for the Philippines indicates that its tax collection efficiency is far from ideal.

A tax system that is fair and just leads to tax compliance. Trust should be established between taxpayers and tax authorities. Thus, a taxpayer’s charter, setting out the basic rights and principles that will also protect taxpayers, is a cornerstone for earning such trust.

Considering how the Philippines encountered major corruption issues in 2025, which certainly dented the government’s reputation, it is about time that a taxpayer’s bill of rights be passed. It will certainly send a message that the government is serious not just about having a fair tax system and boosting investors’ confidence, and can be a very strong signal that the country is serious on its fight against corruption.

Euney Marie J. Mata-Perez is a CPA-Lawyer and the Managing Partner of Mata-Perez, Tamayo & Francisco (MTF Counsel).  She is a corporate, M&A and tax lawyer and has been ranked as one of the top 100 lawyers of the Philippines by Asia Business Law Journal and is the Chair of the Tax Committee of the Management Association of the Philippines. This article is for general information only and is not a substitute for professional advice where the facts and circumstances warrant.  If you have any question or comment regarding this article, you may email the author at info@mtfcounsel.com or visit MTF website at www.mtfcounsel.com.

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