The Bureau of Internal Revenue (BIR) has issued a clarificatory revenue memorandum circular (RMC) to clear up confusion over tax exemptions and incentives for participants in the Enterprise-Based Education and Training (EBET) program and the Adopt-a-School Program, two government initiatives aimed at bridging the country’s growing skills-job gap.
RMC No. 23-2026, released on March 30, addresses certain provisions in Revenue Regulations (RR) 13-2025, which consolidated the rules for claiming tax incentives under the Adopt-a-School Act (RA 8525), the EBET Framework Act (RA 12063), and the Tax Code, The circular aims to encourage more companies to participate in these programs and help public schools and technical institutions upgrade facilities and training programs.
Key clarifications
Under the EBET Act, only enterprises are eligible to implement EBET programs. The BIR clarified that the term “technical-vocational institutions” in RR 13-2025 refers exclusively to enterprises registered with TESDA to operate an EBET framework. Academic institutions are not covered by this designation.
The circular also provides guidance on calculating tax incentives. “Additional deduction” refers to a deduction on top of the regular allowable deductions under Section 34 of the Tax Code. Until December 31, 2027, enterprises can claim 150% of actual training expenses, which includes 100% of the actual cost plus an additional 50% deduction. Starting January 1, 2028, the additional deduction will rise to 75% of training expenses, subject to a cap of 5% of total direct labor expenses or ₱25 million per year, whichever is lower.
RMC 23-2026 clarifies the treatment of training expenses covered by scholarships. EBET programs may be subsidized through scholarships, with general programs covering training costs, assessment costs, and training support funds, while apprenticeship and upskilling programs cover only training and assessment costs. Only expenses actually incurred and shouldered by the enterprise are deductible, while costs funded by third-party scholarships are excluded. Unclaimed EBET incentives cannot be carried over and are forfeited after the applicable taxable year.
The circular also addresses donations under the Adopt-a-School Program. Tax incentives under EBET and Adopt-a-School are mutually exclusive, meaning enterprises may claim only one type of tax incentive for a particular expense or donation. Private entities that adopt public schools can deduct contributions directly incurred for the program, with an additional 50% deduction. These contributions are exempt from donor’s tax. For foreign donations, VAT and excise tax are assumed by TESDA or the Department of Education and the Commission on Higher Education. Local donations may be subject to VAT if they are considered a “transaction deemed sale” of goods originally intended for sale; otherwise, such transfers are VAT-exempt.
Purpose and Impact
The consolidated regulations and RMC are designed to incentivize companies to actively participate in education and skills development initiatives, helping address the mismatch between the labor market’s needs and the country’s workforce capabilities. Under the Tax Code, registered enterprises may claim a 50% additional deduction on labor expenses and a 100% additional deduction on training expenses incurred during the taxable year. The 100% deduction applies only to training provided to Filipino employees directly engaged in the enterprise’s production of goods or services.
For enterprises implementing a registered EBET framework, RR 13-2025 outlines the specific incentives available to technical-vocational institutions, reinforcing the government’s goal of fostering private-sector collaboration in education and workforce development.