Revenue Memorandum Circular No. 081-2024, Tax Treatment of Sukuk (Islamic Bond) as Islamic Banking Arrangement Pursuant to the Tax Neutrality Provision of Republic Act No. 11439 as Implemented by Revenue Regulations No. 17-2020

Revenue Memorandum Circular No. 081-2024 provides for the tax treatment of Sukuk pursuant to the tax neutrality provisions of Republic Act No. 11439. Sukuk are interest-free bonds that generate returns to investors without infringing the principles of Shari'ah which prohibit the payment of interest (riba). 

The circular provides guidelines on the classification and measurement of Sukuk investments by all banks, including Islamic Banks/Islamic Banking Units of Conventional Banks, and Non-Bank Financial Intermediaries. The circular further contains provisions on the taxability of Sukuk issued. It gives examples of the different structures of Sukuk and the corresponding tax neutrality or tax consequence of each.