Senate President Pro Tempore Panfilo Lacson has filed Senate Bill No. 1889, or the Estate Tax Amnesty Act of 2026, which proposes a one-time estate tax amnesty. The measure allows heirs of individuals who passed away on or before December 31, 2025, to settle unpaid estate taxes at a flat rate of 6%.
The bill covers estates with outstanding or accumulated tax liabilities as of that date, regardless of whether the Bureau of Internal Revenue (BIR) has issued an assessment.
“The proposed bill… seeks to enact a broader and more pragmatic Estate Tax Amnesty framework. It authorizes a one-time opportunity for estates of decedents who died on or before a specified date to settle outstanding estate tax liabilities at a uniform rate of 6 percent, subject to simplified documentary and procedural requirements,” Lacson said in the explanatory note.
The measure aims to convert “dormant or unrealized tax exposure” into immediate revenue while allowing the BIR to concentrate on current compliance efforts.
Estates with pending assessments, investigations, or civil and administrative cases can still avail themselves of the amnesty, which applies to the net estate value at the time of death. If an estate tax return was already filed, the 6% rate applies only to undeclared net assets.
Heirs, executors, or administrators must pay a minimum ₱5,000 if allowable deductions exceed the gross estate.
Lacson emphasized that participation in the amnesty does not absolve other liabilities beyond estate taxes:
“Proper parties and the Government retain full authority to pursue forfeiture, recovery, reversion, or criminal prosecution in accordance with applicable law. In this manner, fiscal settlement is compartmentalized from adjudication of substantive rights.”
The bill also includes administrative reforms such as limited documentary requirements, electronic filing and payment, and issuance of a certificate of availment within 15 days.
The BIR would coordinate with regulatory agencies to facilitate property title transfers and bank withdrawals for heirs once amnesty requirements are met.
Lacson highlighted that the measure “widens the taxable universe, accelerates revenue collection, reduces prolonged litigation over tax liabilities, and facilitates the productive reintegration of idle or immobilized assets into the formal economy,” while safeguarding government enforcement authority.
The proposal makes clear that paying the estate amnesty tax does not legitimize unlawful acquisitions, void transactions, or prevent forfeiture, reversion, or recovery of ill-gotten wealth.
Future court rulings on ownership or recovery will not entitle heirs to refunds or credits for amnesty payments already made.