Bill Establishing a Fiscal Regime for the Mining Industry Signed into Law
September 11, 2025
On September 04, President Ferdinand Marcos Jr. signed the “Enhanced Fiscal Regime for Large-Scale Metallic Mining Act,” a measure that mandates mining companies to pay royalty taxes based on their locations. Known as Republic Act (RA) no. 13353, the law proposes, among others:
- To impose royalties on all large-scale mining operations, with different royalties based on the location of the mines in mineral reservations
- To apply windfall profits tax on high commodity prices
- To consolidate the tax structure for Mineral Production Sharing Agreements (MPSA) and Financial or Technical Assistance Agreements (FTAA)
- To provide thin capitalization rules with a debt-to-equity ratio for interest expense deductions (though with different thresholds); and
- To institutionalize public disclosure of extractive industry data.
In comparison to the earlier Senate bill, the law does not prohibit the export of unprocessed ores. Rther, the law authorizes the Bureau of Internal Revenue and Bureau of Customs to examine and audit sales and exportation of minerals and mineral products to ensure that these do not exceed 0.5 percent of the total gross output.
The Department of Finance is directed to draft the Implementing Rules and Regulations (IRRs) of the law within 90 days. The law will come into full effect 150 days after the release of the RA’s copy to the public, or around February 2026.
