The Philippine Chamber of Cooperative Inc. (PH Coop Chamber) filed an appeal before the Supreme Court on Thursday, 10 October 2025, challenging the Bureau of Internal Revenue’s (BIR) memorandum that requires individual cooperative members to provide their Taxpayer Identification Number (TIN) to secure a Certificate of Tax Exemptions (CTE).
“We will challenge the validity of this revenue memorandum circular before the Supreme Court, which we filed today. We argue that these issuances unlawfully restrict the tax exemptions and privileges granted to cooperatives under the cooperative code,” said PH Coop Chamber Secretary General Edwin Bustillos.
The PH Coop Chamber highlighted Republic Act 9520, the Philippine Cooperative Code of 2008, which empowers cooperatives to provide jobs and livelihood to marginalized Filipinos, including business opportunities. However, the BIR regulation has hampered the chamber’s ability to attract more members.
Bustillos explained that their members mainly come from ordinary and vulnerable sectors, and requiring them to provide a TIN adds an unnecessary burden to their already difficult living conditions.
“What we want is for the processes to be easier, so that ordinary members like farmers, fisherfolk, IPs (Indigenous People), and women who go to the BIR are not given a hard time,” Bustillos said in Filipino.“They would rather spend their time farming, fishing, or selling their cooperative's products in the market than be dragged into a bureaucratic process where, at the end of the day, the BIR can only provide ten to twenty TIN numbers,” he added.
PH Coop Chamber Chairperson Noel Raboy said the BIR has imposed this requirement since 2010. While the chamber has tried to comply, factors such as the old age of some members have made compliance difficult.
“We tried to comply with it but lots of cooperatives were already taxed and not given the Certificate of Tax Exemptions because of that,” Raboy said.“Some members are very old already, and because of that, they don’t want to cooperate. We can’t just say that they are not members anymore because they don’t have a TIN,” he added.
Raboy also noted that some members who now face payment penalties with the BIR are negotiating for an amicable settlement.
“The worst case here is those who made transactions without receipts just to finish the process, but that is not good. We worked hard for every peso, ensuring transparency in reporting to the board of directors, management, and the cooperative owners, only to risk losing it all,” Raboy said.“That’s why we said, ‘Enough, these kinds of pressures on the tax exemptions of cooperatives are too much,’” he emphasized.
[Kaya sabi namin, Tama na, sobra na ang mga ganitong klaseng pangigipit sa tax exemptions ng mga kooperatiba.]
