MANILA — Senate President Pro Tempore Panfilo “Ping” Lacson has filed Senate Bill No. 1889, proposing a new Estate Tax Amnesty program covering estates of individuals who died on or before Dec. 31, 2025, with unpaid or accrued estate tax liabilities as of that date.

Dubbed the proposed “Estate Tax Amnesty Act of 2026,” the measure seeks to broaden the tax base, accelerate revenue collection, and reduce prolonged litigation over estate tax cases, while allowing idle or immobilized assets to re-enter the formal economy.

One-time amnesty at 6% rate

Under the bill, qualified estates may settle outstanding estate tax liabilities at a uniform rate of 6 percent of the decedent’s total net estate at the time of death, subject to simplified documentary and procedural requirements.

If an estate tax return had previously been filed with the Bureau of Internal Revenue (BIR), the 6 percent rate will apply only to the net undeclared estate.

If allowable deductions exceed the value of the gross estate, heirs, executors, or administrators may still avail of the amnesty by paying a minimum estate amnesty tax of ₱5,000.

The amnesty may be availed of even if there are pending assessments, investigations, or civil and administrative cases, including actions for recovery of property, forfeiture, or reversion involving estate tax liabilities.

Faster processing, electronic filing

To improve administrative efficiency, the bill:

• Limits documentary requirements
• Allows manual or electronic filing and payment
• Separates tax settlement from property transfer processes

The BIR is required to issue a Certificate of Availment within 15 calendar days from submission of the Acceptance Payment Form and Estate Tax Amnesty Return.

The agency will also coordinate with relevant regulatory offices to facilitate the transfer of property titles to heirs and enable withdrawals from the deceased’s bank accounts.

Amnesty limited to tax liability

Lacson emphasized that payment under the program is meant solely to settle estate tax liability and does not legitimize unlawful acquisitions or void transactions.

The bill explicitly states that availing of the amnesty:

• Does not bar the government from pursuing forfeiture, reversion, recovery of ill-gotten wealth, or criminal prosecution under applicable laws
• Does not extinguish liabilities under laws not covered by the estate tax amnesty
• Does not entitle heirs or beneficiaries to refunds if ownership is later adjudicated in favor of another party or the government

Information declared in the Estate Tax Amnesty Return will remain confidential and cannot be used as evidence in proceedings involving estate tax liabilities covered by the measure.

Revenue and policy goals

According to Lacson, the proposed framework is designed to:

• Convert dormant or unrealized tax exposure into immediate fiscal inflow
• Enhance administrative efficiency
• Allow the BIR to redirect enforcement efforts toward current compliance
• Facilitate productive reintegration of previously immobilized assets into the formal economy

By removing restrictive disqualifications while preserving enforcement safeguards, Lacson said the bill strikes a balance between revenue generation and protection of substantive legal rights.