RR No. 6-2024: The 50% Reduced BIR Compromise Penalty for Micro and Small Taxpayers
RR No. 6-2024 cuts four separate BIR charges in half or more for micro and small taxpayers: the Section 248 surcharge drops from 25% to 10%, Section 249 interest drops from 12% to 6%, the per-document information-return penalty drops from ₱1,000 to ₱500, and RMO No. 7-2015’s compromise penalty for certain invoicing violations is discounted 50%. It implements Section 45 of the Ease of Paying Taxes Act (RA No. 11976) and applies going forward, not to past assessments.
See If You Qualify for the Reduced Micro/Small Rates FREE →This post is the EOPT-driven companion to RMO No. 7-2015 Compromise Penalties Explained and BIR Compromise Penalty Table for Registration, Receipts, and Invoicing Violations — both cite the full-rate schedule this regulation discounts. For the separate one-time abatement program, see RR No. 4-2026: One-Time Tax Abatement for Micro Taxpayers. For the opposite end of the classification scale, see What Is a BIR Large Taxpayer?
What does RR No. 6-2024 actually reduce? #
RR No. 6-2024, issued April 11, 2024, lowers four distinct charges for a covered micro or small taxpayer — the ordinary surcharge, the deficiency interest rate, the flat per-document information-return penalty, and one specific slice of the RMO No. 7-2015 compromise schedule. Each has its own rate change and its own scope.
| Charge | Standard rate | Micro/small rate under RR No. 6-2024 |
|---|---|---|
| Surcharge — late filing, late payment, or unpaid deficiency (Sec. 248) | 25% of amount due | 10% of amount due |
| Surcharge — willful neglect or false/fraudulent return | 50% of tax/deficiency | 50% (no reduction) |
| Interest on unpaid tax (Sec. 249) | 12% per annum | 6% per annum |
| Penalty per missed/incorrect information return, statement, or record (Sec. 250) | ₱1,000, capped at ₱25,000/year | ₱500, capped at ₱12,500/year |
| Compromise for non-fraudulent criminal violation of Secs. 113, 237, 238 (RMO No. 7-2015) | Full Annex A/C schedule amount | 50% of the schedule amount |
The surcharge and interest reductions apply to the same triggers as the standard rules — late filing and payment, an unpaid deficiency assessment, or an unpaid amount shown on a filed return. The one exception RR No. 6-2024 carries over unchanged is willful neglect or a false/fraudulent return, which still draws the full 50% surcharge; a “substantial” under-declaration of sales/income or overstatement of deductions — over 30% of the correct figure — is defined as prima facie evidence of that fraud, and gets no discount.
Which compromise penalties does the 50% discount actually cover? #
RR No. 6-2024’s compromise discount is narrower than it first sounds: it applies only to non-fraudulent criminal violations of NIRC Sections 113, 237, and 238 — VAT invoicing requirements, the duty to issue receipts and invoices, and the printing of receipts and invoices — not to every entry in the RMO No. 7-2015 schedule. Registration violations under Sections 236 and 258, and the Section 255 filing/payment table, sit outside this specific discount.
In the regulation’s own words, the reduced rate is “fifty percent (50%) of the applicable rate or amount of compromise under Annex ‘A’ of Revenue Memorandum Order No. 7-2015 and its subsequent amendments, if any” — for criminal violations of Sections 113, 237, and 238 specifically, not involving fraud.
Worked example: A small taxpayer under RR No. 8-2024 — gross sales of ₱12 million for the year — is found during a tax mapping visit to have issued a first-offense receipt that omits required invoice details, a Section 237 violation. The full-rate compromise for that violation is ₱5,000 (see the registration/receipts compromise table for the full first/second-offense schedule). Because the taxpayer is small and the violation falls under Section 237, RR No. 6-2024’s 50% discount applies: the compromise is ₱2,500, not ₱5,000. Had the same visit instead found an unregistered branch — a Section 236/258 registration violation — the discount would not apply, and the full city/municipality-based amount would stand.
Who qualifies as a micro or small taxpayer? #
Qualification runs on gross sales for the taxable year, using the four-tier classification RR No. 8-2024 set under the same EOPT Act. Only the bottom two tiers get RR No. 6-2024’s reduced rates.
| Classification | Gross sales for the taxable year |
|---|---|
| Micro | Below ₱3,000,000 |
| Small | ₱3,000,000 to below ₱20,000,000 |
| Medium | ₱20,000,000 to below ₱1,000,000,000 |
| Large | ₱1,000,000,000 and above |
“Gross sales” for this classification means total sales revenue, net of VAT where applicable, covering business income only — it excludes compensation income earned under an employer-employee relationship, passive income taxed under Sections 24, 25, 27, and 28, and income excluded under Section 32(B) of the Tax Code. A taxpayer who registers to start a business after RR No. 8-2024 took effect is initially classified from their declared figures on the registration form; a taxpayer already registered in or before 2022 is classified using actual 2022 gross sales, and one without submitted 2022 figures (or registered in 2023/2024 before the regulation’s effectivity) starts as micro — except a VAT-registered taxpayer, who starts as small.
Frequently asked questions #
What is RR No. 6-2024? #
RR No. 6-2024, issued April 11, 2024, implements Section 45 of the Ease of Paying Taxes Act (RA No. 11976) by imposing reduced interest and penalty rates on micro and small taxpayers — a lower surcharge, lower interest, a lower information-return penalty, and a 50% discount on covered RMO No. 7-2015 compromise penalties.
How much is the surcharge for a micro or small taxpayer under RR No. 6-2024? #
10% of the amount due for failure to file a return and pay tax on time, failure to pay a deficiency tax within the assessment notice’s deadline, or failure to pay the full tax shown on a filed return — versus the standard 25% surcharge under Section 248 for other taxpayers. Willful neglect or a false/fraudulent return still carries the full 50% surcharge regardless of taxpayer size.
Does the RR No. 6-2024 compromise discount apply to every violation? #
No. The 50% discount applies only to non-fraudulent criminal violations of NIRC Sections 113, 237, and 238 — VAT invoicing, issuance of receipts and invoices, and printing of receipts and invoices. It does not reduce the Section 236/258 registration compromise table or the Section 255 filing/payment compromise table.
Who qualifies as a micro or small taxpayer? #
RR No. 8-2024 defines a micro taxpayer as one with gross sales under ₱3 million for the taxable year, and a small taxpayer as one with gross sales from ₱3 million to under ₱20 million. Gross sales covers business income only — compensation income and passive income under Sections 24, 25, 27, and 28 are excluded from the computation.
Does RR No. 6-2024 apply to assessments issued before April 2024? #
No. The regulation states it applies prospectively, in accordance with Section 51 of RA No. 11976. Violations and deficiencies from before its effectivity are assessed under the standard rates that applied at the time.
Summary #
RR No. 6-2024 is a targeted EOPT relief measure, not a blanket discount: micro and small taxpayers get a lower surcharge (10% vs. 25%), lower interest (6% vs. 12%), a lower information-return penalty (₱500 vs. ₱1,000 per failure), and a 50% cut on RMO No. 7-2015 compromise — but that last discount reaches only Section 113, 237, and 238 invoicing violations, not registration or filing/payment compromise. Confirm your RR No. 8-2024 classification first, then check which table your specific violation sits on before assuming the discount applies.