TRANSACTION COUNT- HOW?

Here’s something that’s been nagging me — and maybe other people in real estate too, though I might be alone on this island — how does the BIR actually count real estate transactions?

You see, there’s a rule: if you’ve had six or more real estate transactions in the preceding year, the BIR will label you as “habitually engaged” in the real estate business. Sounds harmless? Well, not quite — because once you’re tagged, all your future deals will be slapped with VAT and income tax. 🧾

But here’s the kicker: what counts as a “transaction”?

Let’s say you sell three adjacent lots in one go. You execute one Deed of Absolute Sale (DOAS) — is that just one transaction? Or three?

What if you sell a condo unit with a parking slot — does that count as one deal or two? (Assuming they’re covered under a single title.)

And are we just talking about sales? Or do purchases get counted too?

After digging through old files and Certificate Authorizing Registration (CAR) documents, here's what I found:

+ The BIR counts titles, not DOAS.

+ Each title gets its own CAR, even if covered by just one DOAS.

+ Each CAR has a unique transaction number — and these numbers are what the BIR counts.

+ Both sales and purchases are included in the tally.

So, selling a 3-bedroom condo with three separate parking slots (four titles in total)?

That’s four transactions in the eyes of the BIR.

Heads up: If you're not planning to be tagged as habitually engaged (and avoid the extra taxes that come with it), keep a close eye on those title counts.