THE Bureau of Internal Revenue (BIR) has streamlined the tax process for corporate-owned country club and sports club memberships, removing a major administrative hurdle for businesses transferring shares between corporate nominees.
Under the newly issued Revenue Memorandum Circular (RMC) No. 72-2026, dated June 30, 2026, the BIR clarified that transferring proprietary club shares between corporate nominees is not subject to Capital Gains Tax, Documentary Stamp Tax, or Donor’s Tax, provided there is no change in actual beneficial ownership.
Crucially, the circular eliminates the previous requirement for companies to secure a prior confirmatory ruling from the bureau before executing these transactions.
BIR Commissioner Charlito Martin R. Mendoza stated that the policy shift is part of the BIR DARES initiative, which aims to make tax compliance simpler and more taxpayer-focused.
“Clearer rules lead to more efficient tax administration and greater peace of mind for taxpayers,” Mendoza said. “By removing the need for a prior confirmatory ruling, we are reducing unnecessary administrative burden while ensuring that compliance continues to be verified through post-audit.”
The guidelines apply specifically to proprietary club shares that are legally owned by a corporation but registered under the name of an individual officer to comply with club membership rules.
To qualify for tax-exempt status, companies must meet strict conditions:
- The corporation must remain the sole beneficial owner.
- The nominee must hold the legal title under a formal Declaration of Trust or Trust Agreement.
- The share must be recorded as a corporate asset.
- No monetary or non-monetary consideration can be exchanged between the outgoing and incoming nominees.
Following the directive, the BIR will no longer act on pending requests for confirmatory rulings.
Taxpayers can now proceed directly to their respective Revenue District Offices (RDO) to process the necessary electronic Certificate Authorizing Registration (eCAR).
Commissioner Mendoza emphasized that the bureau will maintain oversight and ensure compliance through strict post-audit verifications.
