CLARIFYING THE INSTRUMENTS EMBRACED BY THE TERM “DEPOSIT SUBSTITUTES” UNDER REVENUE REGULATIONS NO. 8-2008
an alternative form of obtaining funds from the public (i.e. twenty
(20) or more individual or corporate lenders at any one time), other
than deposits, through the issuance, endorsement, or acceptance of debt
instruments for the borrower’s own account, for the purpose of relending
or purchasing receivable and other obligations, or financing their own
needs or the need of their agents or dealers”.
For purposes of clarifying what instruments qualify as ‘deposit
substitutes’ under Revenue Regulations No. 8-2008, such term may include
other instruments described in Section 22 (Y) of the National Internal
Revenue Code of 1997, as amended, viz, xxx xxx xxx. These
instruments may include, but need not be limited to, bankers’
acceptances, promissory notes, repurchase agreements, including reverse
repurchase agreements entered into by and between the Bangko Sentral ng
Pilipinas (BSP) and any authorized agent bank, certificates of
assignment or participation and similar instruments with recourse:
Provided, however, that debt instruments issued for interbank call loans
with maturity of not more than five (5) days to cover deficiency in
reserves against deposit liabilities, including those between or among
banks and quasi-banks, shall not be considered as deposit substitutes
debt instruments”.
All internal revenue officers are hereby enjoined to give this Circular as wide a publicity as possible.
Adopted: 09 Feb. 2009
(SGD.) SIXTO S. ESQUIVIAS IV
Commissioner of Internal Revenue