June 28, 2023

REVENUE MEMORANDUM CIRCULAR NO. 12-2024

SUBJECT : Clarifies the Treatment of Foreign Currency Transactions

for Financial Reporting and Internal Revenue Tax
Purposes

TO : All Internal Revenue Officials, Employees, and Others

Concerned

This Circular is hereby issued to clarify the differences between the

foreign exchange (forex) gains/losses recognized in the financial statements
prepared under the Philippine Financial Reporting Standards
(PFRS)/Philippine Accounting Standards (PAS) and the forex gains/losses as
income or allowable deduction for income tax purposes pursuant to the
provisions under Sections 32 and 34 (D) of the National Internal Revenue
Code (NIRC) of 1997, as amended, Sec. 96 of Revenue Regulations (RR) No.
02-40, RR No. 06-2006, and other related revenue issuances. SDAaTC

This is also issued to clarify and prescribe the guidelines on the use of
appropriate forex rates in recording and reporting foreign currency
transactions for tax purposes.
For purposes of this Circular, the Philippine Peso (PhP) is considered as
the functional currency and other currencies are considered as foreign
currency. This Circular does not cover Banks and other Financial Institutions
and those using functional currency other than Philippine Peso in the
financial statements.
I. DEFINITION OF TERMS
The following terminologies as defined below shall only be applicable
to the references made to such terms under this Circular.
Foreign Currency — is a currency other than the functional currency
of the reporting entity (e.g., currency other than PhP).
Functional Currency — is the currency of the primary economic
environment in which the reporting entity operates; that is the currency of
the environment in which an entity primarily generates and expends cash.
Foreign Currency Transactions — are transactions denominated in
any currency other than functional currency for a particular entity.
Foreign Exchange Rate — is the price of a unit of foreign currency in
terms of the domestic currency. For example, the exchange rate is
conventionally expressed as the value of one United States Dollar (USD) in
PhP equivalent (e.g., US$1 = P50.00).
Forex Spot Rate — is the current exchange rate at which a currency
can be bought or sold.
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 Interbank Reference Rate — is the exchange rate that banks pay
when they engage in currency trades with other banks. AaCTcI

Closing Rate — is the final price at which a currency is traded at the

end of the forex trading day.
Foreign Currency Conversion — is the conversion of one currency
into another at a specific rate known as the foreign exchange rate.
Foreign Currency Translation — is an accounting method of
restatement, in the currency in which a company presents its financial
statements, of all assets, liabilities, revenues and expenses that are
denominated in foreign currencies.
Remeasurement — is the process of re-establishing the value of an
asset or foreign currency to provide a more accurate financial record of its
value on a company's financial statements. Remeasurement is often used by
companies that conduct business in multiple currencies.
Other Comprehensive Income (OCI) — this includes revenues,
expenses, gains and losses that are yet to be realized for accounting
purposes and are excluded from net income (e.g., foreign currency
translation gains or loss, unrealized gain or loss on investment that are
available for sale, etc.)
Closed and Completed Transaction — is a taxable event that has
been consummated as fixed by identifiable events occurring in a particular
year (e.g., actual sale or disposition of asset, etc.).
II. TABULAR LIST OF DIFFERENCES

PARTICULARS PFRS Current Tax

Treatment

1. Initial All foreign currency Foreign currency

measurement of transactions are transactions are
foreign currency recorded in the translated into
transactions entity's functional Philippine Peso using
currency using the the prevailing interbank
spot rate of exchange reference rate on the
at transaction date. date of transaction. 1

This is the basis of the

reportable transactions
for taxes other than
income tax (e.g., VAT,
GRT, OPT, Excise, DST,
etc.)

2. Unrealized gain or Recognized in profit Results to a temporary

loss on or loss. difference for which
remeasurement of deferred tax accounting
monetary assets should be applied to
and liabilities reconcile accounting
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 denominated in net income to taxable
foreign currency net income.

3. Unrealized gain or Recognized in profit Not considered in the

loss on or loss or OCI determination of the
remeasurement of depending on the taxable income.
non-monetary treatment of the
items carried at fair changes in the fair
value currency value of the item
transaction itself.

4. Realized gain or Recognized in profit Forex gains/losses

loss on settlement or loss. arising from closed and
of a foreign completed transactions
currency are considered as
transaction taxable income or
deductible expense for
income tax purposes. 2

III. PFRS TREATMENT

PAS 21 requires an entity to determine its functional currency taking
into account the primary economic environment in which an entity operates.
Once the entity has determined its functional currency, all other currencies
are treated as foreign currencies. acEHCD

Initial Measurement
A foreign currency transaction is recorded initially using the rate of
exchange on the date of the transaction. The use of average rate is
permitted as long as they are a reasonable approximation of the actual. (PAS
21.21-22)
Subsequent Measurement
At each reporting date (PAS 21.23):
• Foreign currency monetary amounts are reported using the
closing rate. Any unrealized gain or loss arising from the
translation of monetary assets and liabilities the end of the
reporting period is generally recognized in profit or loss.
• Non-monetary items carried at historical costs are measured
using the historical exchange rate at the date of the transaction.
This means that they are not remeasured reporting date.
• Non-monetary items that are carried at fair value are translated
using the exchange rates at the date the fair value is measured.
Any unrealized gain or loss arising from the translation is
recognized in the same way the change in fair value is
recognized in the financial statements. For example, when the
change in the fair value of a non-monetary item is recognized in
OCI, then unrealized gain or loss arising from the translation shall
also be recognized in OCI.

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 Settlement
When monetary items are settled, the difference between the carrying
amount of the monetary asset or liability and the consideration
received/paid is recognized immediately in profit or loss.
IV. CLARIFICATION ON ISSUES INCLUDING GUIDELINES RELATIVE
TO THE TAX TREATMENT OF FOREIGN CURRENCY
TRANSACTIONS
Q1: For tax reporting purposes, how are foreign currency
denominated transactions measured?
A1: Foreign currency transactions shall be converted into functional
currency using the exchange rate at the time an asset, liability, income and
expense are recognized and measured/remeasured (i.e., the date of
transaction, reporting date, settlement date). EcTCAD

Q2: In relation to Q&A No. 1, what is the exchange rate to

be used at initial recognition of foreign currency denominated
transactions?
A2: The spot rate on the date of transaction shall be used.
Since the forex spot rates change from time to time within a particular
day depending on the market trading activities, different forex spot rates are
being published every trading day (e.g., open, close, high, low, weighted
average, etc.) as a reference rate to be adopted for proper valuation
reflecting the true income of foreign currency denominated transactions.
Then, for purposes of this Circular, the taxpayer has the preference to
adopt which spot rate to be used (e.g., open, close, high, low, weighted
average, etc.) in the beginning of the taxable year as long as the spot rates
adopted must be used consistently both in recording for financial accounting
purposes and reporting for tax purposes for at least one taxable year.
Q3: What exchange rate shall be used in converting foreign
currency denominated transactions incurred on dates where there
are no published forex rates available (e.g., weekends, holidays,
etc.)?
A3: Use the latest closing spot rate available on the business date
immediately preceding the date of transaction.
For example, Company A sold goods at $100 on November 30, 2022.
No available forex data available on the said date since it falls on a holiday.
The most recent closing spot rate available is that of November 29, 2022.
Company A should convert its foreign currency transaction of $100
using the closing spot rate on November 29, 2022.
Q4: What should be the source of forex rates to be used in
converting foreign currency denominated transactions for tax
purposes?
A4: To standardize the forex rates to be used for tax purposes, the
following rules are hereby prescribed to govern the conversion of foreign
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 currency denominated transactions to Philippine Peso:
a. The spot rate of exchange on the day of the transaction based on
the Banker's Association of the Philippines (BAP) 3 published
rates; 4 or
b. In the event that the forex rate as stated in item (a) is
impractical or not feasible, the spot rate on the day of the
transaction based on other available exchange rates (e.g.,
Bangko Sentral ng Pilipinas (BSP), Bloomberg, Reuters exchange
rates, etc.) shall be used subject to the following conditions: SDHTEC

1. A taxpayer electing to use forex rates other than BAP

published rates must submit to the Revenue District Office
(RDO) or Large Taxpayer District Office (LTDO) or Large
Taxpayers Service (LTS) whichever has jurisdiction over the
taxpayer, a notarized sworn statement stating the source of
the forex rates to be used, the reason for using such forex
rates other than BAP published rates and a statement
allowing the BIR to have an access on the day-to-day forex
rates used during BIR audit (e.g., access to subscription with
Bloomberg, etc.) for the taxable year, within 30 days prior
to the start of the taxable year.
2. The source of forex rates used in converting foreign
currency denominated transactions, such as the URL/source
where the forex rates are published or listed or a summary
of the day-to-day exchange rates used for the taxable year
must be available for presentation and submission, together
with other supporting documents during BIR audit.
Election of forex rates are irrevocable and must be used consistently
both in recording for financial accounting purposes and reporting for tax
purposes for at least one taxable year.
The notarized sworn statement informing the concerned BIR offices of
electing the use of forex rates other than BAP published rates shall be
submitted. In case of subsequent change in forex rates used, a new notice
shall be submitted to the concerned BIR office, which shall be applied from
the start of the succeeding taxable year.
Q5: How many decimal places on forex rates should be used
when converting foreign currency denominated transactions?
A5: Use the actual forex rates as published or listed based on the
reference exchange rates opted in Q&A No. 4.
In case the taxpayer's accounting system is not capable of adopting
the exact number of decimal places as of those in the forex published rates,
the taxpayer may use the maximum number of decimal places as designed
in their respective system subject to written notification to the BIR office
whichever has jurisdiction over the taxpayer for the system limitation. HSAcaE

Q6: In relation to Q&A No. 4, what should be the source of

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 forex rates to be used if the foreign currency transaction involved is
denominated in a currency other than USD?
A6: Given that BAP publishes USD/PhP spot rates only, taxpayers
with foreign currency transactions other than USD are allowed to directly
convert the foreign currency other than USD to PHP using the forex rates
other than BAP published rates as stated in Q&A (4) (b) above following the
conditions enumerated.
Q7: What if the taxpayer incurred a foreign currency
denominated transaction other than USD in the middle of the
taxable year but initially elected to use BAP published rates?
A7: The taxpayer is allowed to use the BSP spot rates for foreign
currency transaction other than USD subject to the following conditions:
a. The taxpayer shall summarize its foreign currency transactions
other than USD with the following information:
1. Date of transaction
2. Amount of foreign currency transactions other than USD
3. Nature of transaction
4. Forex rate used in converting to PhP; and
5. PhP converted amount of the foreign currency transaction
b. The requirement on item (a) must be available for presentation
and submission, together with the supporting documents on the
said foreign currency transactions during BIR audit.
Q8: What if the taxpayer used forex rates other than BAP
published rates but failed to notify the BIR as required under Q&A
No. 4 (b) (1)?
A8: The taxpayer will still be required to prove the reliability of
exchange rate used during a tax audit. Moreover, corresponding
administrative penalties under Section 255 of the Tax Code, as amended,
would be imposed for first and second offenses. Subsequent offenses shall
be considered as willful failure, and thus not subject to compromise.
In the absence of any proof, the forex rates other than BAP published
rates used by the taxpayer shall be disregarded during BIR audit. In case of
foreign currency transactions denominated in USD, the same shall be
converted using the BAP published rates, whereas for foreign currency
transactions denominated in a currency other than USD, the BSP rates shall
be used.
Q9: Is the conversion prescribed under RMC 26-1985 for
currencies other than the USD mandating to convert first the
foreign currencies to USD using the prevailing exchange rate
between the two currencies, now superseded?
A9: Yes. With the availability of wide range of forex between
foreign currencies other than USD to PhP, the practice of converting first to
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 USD the foreign currency other than the USD is now superseded by Q&A No.
4 (b) and Q&A No. 6 of this Circular. AScHCD

Q10: Is the use of monthly average exchange rates

permitted in converting foreign currency transactions to Philippine
peso for tax purposes?
A10: No. Foreign currency transactions are converted into
Philippine peso for tax purposes using the spot rate of exchange on the date
of transaction.
Q11: What is a foreign exchange difference?
A11: A forex difference (i.e., gains/losses) results when there is a
change in the exchange rate between the transaction date, balance sheet
date and the date of settlement of any monetary items arising from a
foreign currency transaction.
Unrealized forex gains/losses results from fluctuations in exchange
rates upon remeasurement between the transaction date and the balance
sheet date. It is only a potential gain/loss where there is no real flow of
wealth yet generated from the remeasurement for accounting purposes.
Realized forex gains/losses results from changes in the exchange rates
between the transaction date and the date of settlement. This represents the
actual gains/losses incurred from a closed and completed foreign currency
transactions.
Q12: Are gains/losses arising from forex fluctuations on
remeasurements of monetary and non-monetary assets and
liabilities denominated in foreign currency included in the
determination of the taxable income for income tax purposes?
A12: The "Realization" principle adopted under RR No. 02-40 5
provides that for purposes of taxation, only the realized gain or loss from
foreign exchange transaction will be subject to income tax. Under this
principle, income is recognized when: (i) the earning process is complete or
virtually complete, and (ii) an exchange has taken place.
Unrealized gains or losses on forex fluctuations recognized in
connection with the periodic remeasurement of assets and liabilities
denominated in foreign currency to functional current are not considered as
income/loss for purposes of computing taxable income. Such differences are
temporary and should be monitored for which deferred tax accounting
should be applied. These temporary differences will reverse when the
respective assets and liabilities are disposed of or settled. These temporary
differences which give rise to deferred tax assets/liabilities are required to be
disclosed in the Notes of Audited Financial Statements (AFS).
Q13: Are taxpayers required to separately record and
report unrealized and realized forex gains/losses for income tax
purposes?
A13: The taxpayers should separately record and report unrealized
forex gains/losses from the realized forex gains/losses arising from foreign
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 currency transactions. HESIcT

Only realized forex gains/losses, or those arising from closed and

completed transactions, are considered as taxable income or deductible
expense for income tax purposes. Realized forex gains/losses shall be
substantiated with sufficient evidence that the same arose from a closed and
completed transaction (e.g., schedule of foreign currency transactions
resulting to forex gains/losses with reference to the bank statements on
actual collection of receivables and payment of payables, etc.).
Moreover, automatic reversal of unrealized forex differences to realized
forex gains/losses in the succeeding year not arising from closed and
completed transactions are strictly prohibited for income tax purposes.
Q14: What are examples of events that will give rise to an
actual gain or loss reportable for tax purposes?
A14: Difference in foreign exchange rates will give rise to actual
gain/loss when certain events occur, 6 such as, but not limited to the
following:
• Exchange rate at the time of receipt of advance payments on
contracts is different from the rate at the time income is earned
and debited against advance payments;
• Exchange rate at the time of recording/recognizing accounts
receivables is different from the rate at the time of actual
collection of the account receivables;
• Exchange rate at the time advance payments are made to
subcontractors is different from the rate at the time expenses on
the sub-contract are incurred/recorded;
• Exchange rate at the time of recording/recognizing accounts
payables is different from the rate at the time accounts payables
are paid;
• Exchange rate at the time down payments for construction
materials are made is different from the rate at the time of full-
payment/settlement of the balance on the purchase price of the
materials.
Q15: Is netting or offsetting of forex gains and losses
allowed for income tax purposes?
A15: The practice of offsetting transactions of taxpayers and
consequently the accounting and recording of the same and its related
transactions in the books of the parties is strictly prohibited for taxation
purposes. 7 AcICHD

The gross amounts of gain and loss must be presented in the income
tax return. However, for tax calculation purposes, forex loss is still allowed
as a deduction following the rules on income tax deductibility.
Q16: Where will forex gains and losses be presented in the
income tax returns?
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 A16: Forex gains shall be presented as part of "Other Taxable
Income" and be included in the computation of "Total Taxable Income" or
"Gross Taxable Income" in the income tax return.
On the other hand, forex losses shall be presented as part of the
"Ordinary Allowable Itemized Deductions" in the income tax return.
Q17: What will be the basis for the reportable amount of
transactions denominated in foreign currency for taxes other than
the income tax (e.g., Value-Added Tax (VAT), Gross Receipt Tax
(GRT), Other Percentage Taxes (OPT), Excise Tax, Documentary
Stamp Tax (DST), etc.)?
A17: Foreign currency transactions are converted into Philippine
Peso using the prevailing spot rate on the date of transaction. This is the
basis of the reportable transactions for taxes other than income tax ( e.g.,
VAT, GRT, OPT, Excise, DST, etc.).
For VAT purposes, the reportable amount for sale of goods or
properties shall be the gross selling price or the gross value in money as
supported by a corresponding sales invoice; while for sale or exchange of
services, including the use or lease of property, it shall be the gross receipts
as supported by a corresponding official receipt.
For GRT and OPT, the reportable amount shall be the gross quarterly
sales or receipts depending on the type of transaction subject to the said
taxes.
For Excise, the reportable amount shall be the excise taxes imposed
and based on weight or volume capacity or any other physical unit of
measurement (specific tax) and imposed and based on selling price or other
specified value of the goods (ad valorem tax) generally before the
removal/release of the excisable products.
For DST, the reportable amount shall be based on the value of the
documents subject to stamp tax.
For withholding taxes, in general, the reportable amount shall be the
value of the taxable income payment at the time it is paid or payable or
when it is accrued or recorded as an expense or asset whichever comes
first.
Illustrations and Accounting Entries are reflected in the Annex "A"
hereof, as guide for recording and reporting foreign currency transactions. caITAC

All revenue issuances and BIR rulings inconsistent herewith are hereby
considered amended, modified or revoked accordingly. Interpretations in BIR
rulings and court rulings cited in this Circular can be subject to change under
prevailing circumstances of latest court decisions and new laws enacted
affecting the subject matter.
All internal revenue officers, employees and others concerned are
hereby enjoined to strictly implement the provision of this Circular.
This Circular takes effect immediately.

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 (SGD.) ROMEO D. LUMAGUI, JR.
Commissioner of Internal Revenue
ANNEX A
Illustration and Accounting Entries
For clarification and to guide the concerned taxpayers in recording and
reporting foreign currency transactions, hereunder are illustrations involving
foreign currency denominated transactions together with the corresponding
accounting entries.
ILLUSTRATION NO. 1
Company A is a VAT-registered domestic entity engaged in the export sale
of goods. Company B is a non-resident foreign corporation (NRFC) which is a
regular customer of Company A.
On December 1, 2022, Company A sold goods to B worth $1,000,000.00
and issued the corresponding zero-rated sales invoice for the same amount. On
January 10, 2023, Company B remitted $1,000,000.00 to Company A for which
the latter issued the corresponding collection receipt. On the same day, Company
A's bank credited the corresponding collection of $1,000,000.00 into its Peso
account using the prevailing spot rate of exchange.
Below are the forex rates on the following dates:

Measurement Date Date Forex Rate

Initial Measurement December 1, US$1.00 :

2022 PhP50.00

Subsequent December 31, US$1.00 :

Measurement 2022 Php51.00

Settlement Date January 10, 2023 US$1.00 :

Php50.50

Based on the foregoing, A should have the following entries in its books:
A. To record the sale of goods of Company A to Company B on
December 1, 2022

Particulars Debit Credit

Accounts Receivable ($1,000,000 x P50,000,000.00

P50)

Sales P50,000,000.00

B. To record the subsequent measurement on balance sheet date on

December 31, 2022 TAIaHE

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 Particulars Debit Credit

Accounts Receivable ($1,000,000 x P1,000,000.00

P1)

Unrealized Forex Gain P1,000,000.00

C. To record the deferred tax entry on the temporary difference on

forex (assuming corporate income tax rate of 25%) for year 2022

Particulars Debit Credit

Income Tax Expense — Deferred P250,000.00

Deferred Tax Liability (P1,000,000 x P250,000.00

25%)

D. To record income tax payable for Year 2022. Assuming, Company A

has a corresponding Cost of Sales amounting to P30,000,000.00 and
operating expenses of P5,000,000.00, gross of unrealized forex loss.
Net Taxable Income for the year is P15,000,000.00.

Particulars Debit Credit

Income Tax Expense (P15,000,000 x P3,750,000.00

25%)

Income Tax Expense Deferred P250,000.00

Income Tax Payable P3,750,000.00

Deferred Tax Liability (P1,000,000 x P250,000.00

25%)

For income tax purposes, income tax payable is P3,750,000.00.

E. To record the collection of payment on the sale of goods (year 2023)

Particulars Debit Credit

Cash ($1,000,000 x P50.50) P50,500,000.00

Realized Forex Loss (1,000,000 x P500,000.00

P0.50)

Accounts Receivable P51,000,000.00

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 F. To record the realization of unrealized forex gain upon collection
(year 2023)

Particulars Debit Credit

Deferred Tax Liability (P1,000,000 x P250,000.00

25%)

Income Tax Expense — Deferred P250,000.00

G. To record income tax payable for Year 2023

Particulars Debit Credit

Deferred Tax Liability (P1,000,000 x P250,000.00

25%)

Income Tax Expense — Current P125,000.00

(P500,000 x 25%)

Income Tax Expense — Deferred P250,000.00

Income Tax Payable P125,000.00

For income tax purposes, income tax payable is P125,000.00. ICHDca

ILLUSTRATION NO. 2
Company C is a VAT-registered domestic entity engaged in manufacturing
of electronic parts. Company D is a NRFC engaged in supplying machine and
equipment used in manufacturing electronic parts.
On November 15, 2022, Company C purchased a capital equipment worth
$2,000,000.00, of which $500,000.00 was paid as downpayment, from D which
the latter issued the corresponding invoice and receipt. On February 6, 2023, the
imported equipment arrived in the Philippines for which C paid the corresponding
taxes in the customs. On the same day, Company C paid D the outstanding
balance of $1,500,000.00 on the purchase of the said equipment.
Below are the forex rates on the following dates:

Measurement Date Date Forex Rate

Initial Measurement November 15, US$1.00 : PhP49.50

2022

Subsequent December 31, US$1.00 : Php51.00

Measurement 2022

Settlement Date February 06, US$1.00 : Php51.25

2023
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 Based on the foregoing, C should have the following entries in its books:
A. To record the purchase of imported equipment by Company C to
Company D on November 15, 2022. Assuming, it is the practice of
Company C to record its equipment based on the date of the invoice.

Particulars Debit Credit

Equipment ($2,000,000 x P49.50) P99,000,000.00

Cash ($500,000 x P49.50) P24,750,000.00

Accounts Payable ($1,500,000.00 x P74,250,000.00

P49.50)

B. To record the subsequent measurement on balance sheet date on

December 31, 2022

Particulars Debit Credit

Unrealized Forex Loss P2,250,000.00

Accounts Payable ($1,500,000.00 x P2,250,000.00

P1.50)

C. To record the deferred tax entry on the temporary difference on

forex (assuming corporate income tax rate of 25%) for year 2022 cDHAES

Particulars Debit Credit

Deferred Tax Asset (P2,250,000 x P562,500.00

25%)

Income Tax Benefit — Deferred P562,500.00

D. To record income tax payable for Year 2022. Assuming, Company C

has a net income from operations amounting to P60,000,000.00,
gross of unrealized forex loss.

Particulars Debit Credit

Income Tax Expense (P60,000,000 x P15,000,000.00

25%)

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 Deferred Tax Asset (P2,250,000 x P562,500.00
25%)

Income Tax Benefit — Deferred P562,500.00

Income Tax Payable P15,000,000.00

For income tax purposes, income tax payable is P15,000,000.00.

E. To record the payment of taxes on customs and the payment of
outstanding balance on the purchase of equipment. Assuming the
other taxes is P200,000.00 (year 2023)

Particulars Debit Credit

Accounts Payable P76,500,000.00

Realized Forex Loss ($1,500,000 x P375,000.00

P0.25)

Input VAT (99,000,000 x 12%) P11,880,000.00

Other Taxes (Customs Duties, etc.) P200,000.00

Cash P88,955,000.00

F. To record the realization of unrealized forex loss upon payment (year

2023)

Particulars Debit Credit

Income Tax Benefit — Deferred P562,500.00

Deferred Tax Asset (P2,250,000 x P562,500.00

25%)

G. To record income tax payable for Year 2023. Assuming, Company C

has gross income of P5,000,000.00 during the year. TCAScE

Particulars Debit Credit

Income Tax Expense — Current P543,750.00

Income Tax Benefit — Deferred P562,500.00

Deferred Tax Asset (P2,250,000 x P562,500.00

25%)

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 Income Tax Payable P543,750.00

Income Tax Expense – Current = [P5,000,000 (GI) – P375,000 (2023

Realized Forex Loss) – P200,000 (Other Taxes – P2,250,000 (2022
Forex Loss Realized in 2023)] x 25%

For income tax purposes, income tax payable is P543,750.00.

Footnotes

1. Revenue Memorandum Circular (RMC) No. 26-85, dated duly 15, 1985.
2. RR No. 2 — Income Tax Regulations.

3. The Philippine Dealing System (PDS) rates used as interbank reference rate per
RR No. 06-2006 already ceased publishing the FX spot summary rates
pursuant to BAP advisory dated March 16, 2018.
4. www.bap.org.ph/markets/

5. RR No. 2 — Income Tax Regulations.

6. BIR Ruling [DA-359-03], dated October 10, 2003.

7. Revenue Memorandum Circular No. 61-2016 — Prescribing Policies and

Guidelines for Accounting and Recording Transactions Involving "Netting" or
"Offsetting."

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