Section 28Sec./Art. 28

Transfer of Assets. - The sale or transfer of assets to the SPE, which includes sale or transfer of any and all security interest thereto, it made in accordance with the Plan shall be exempted from value-added tax (VAT) and documentary stamp tax (DST), or any other taxes imposed in lieu thereof. Except for registration fees with the Commission, all applicable registration and annotation fees to be paid, related or incidental to the transfer of assets, or the security interest thereto, shall be fifty percent (50%) of the applicable registration and annotation fees.

The transfer of assets by dation in payment (dacion en pago) by the obligor in favor of an SPE shall not be subject to capital gains tax as provided under Section 27 (d)(5) of the National Internal Revenue Code of 1997.