I. Concept and Nature of Zonal Valuation

Zonal valuation is the system established by the Bureau of Internal Revenue (BIR) whereby the Commissioner of Internal Revenue divides the Philippines into different zones and prescribes the fair market value per square meter (or per hectare in certain cases) of real properties within each zone for internal revenue tax purposes.

The zonal value is a government-imposed minimum valuation that operates as an irrebuttable presumption of value for the computation of:

Capital Gains Tax (6% final tax under the TRAIN Law)
Creditable Withholding Tax on sales by property developers
Documentary Stamp Tax on transfers (1.5%)
Donor’s Tax
Estate Tax

The rule is explicit: the tax base shall be the higher between the gross selling price/consideration and the zonal value as determined by the BIR, or the fair market value in the latest Tax Declaration, whichever is highest.

Agricultural lands are assigned separate zonal values that are invariably lower than residential, commercial, or industrial classifications in the same vicinity, precisely because they remain classified as agricultural under existing tax declarations and local government schedules of market values.

II. Legal Basis

The authority of the Commissioner of Internal Revenue to establish and revise zonal values is derived from:

Section 6(E) of the National Internal Revenue Code of 1997 (Republic Act No. 8424), as amended, which grants the CIR the power “to obtain on a regular basis from any person or office, data or information necessary for the proper discharge of his functions, including real property valuations.”
Presidential Decree No. 76, as amended by P.D. Nos. 261, 921, 1621, and 1993, which originally mandated the establishment of zonal values.
Revenue Regulations No. 2-98, as amended, and subsequent Revenue Memorandum Orders (RMOs) that publish the revised zonal values per Revenue District Office (RDO).
Department of Finance Order No. 29-92 and subsequent DOF issuances requiring consultation with local assessors and real estate stakeholders before final approval of revisions.

III. Classification of Agricultural Lands for Zonal Valuation Purposes in Bulacan

The BIR classifies agricultural lands in Bulacan into the following major categories (as reflected in the latest published schedules covering RDO Nos. 24, 25-A, 25-B, 26, and 27):

Riceland (irrigated, rainfed, upland)
Corn land
Sugarcane land
Coconut land
Mango orchard and other fruit-bearing tree plantations
Fishponds (bangus and prawn)
Pasture land
Vegetable land
Idle/vacant agricultural land

Each subcategory commands a different zonal value per square meter, with irrigated riceland usually having the highest value among purely agricultural classifications, followed by fishponds in coastal municipalities.

IV. Revenue District Offices Covering Bulacan and Their Respective Zonal Value Editions (as of December 2025)

As of the latest consolidated issuances:

RDO No. 24 – Malolos City, Bulacan (covers Malolos City, Calumpit, Hagonoy, Paombong, Pulilan, Bulakan, Guiguinto, Plaridel, Baliuag)
Current edition: 10th Revision (effective 2024–2029 under RMO No. 32-2024)
RDO No. 25-A – Meycauayan East (Meycauayan City east of NLEX, Marilao, Bocaue, Santa Maria, Pandi)
Current edition: 11th Revision (effective 2023–2028 under RMO No. 18-2023, with partial upward adjustments in 2025)
RDO No. 25-B – Meycauayan West (Meycauayan west, Obando, Valenzuela portions bordering Bulacan)
Current edition: 10th Revision
RDO No. 26 – San Jose del Monte City (covers SJDM City, Norzagaray, Angat, Doña Remedios Trinidad)
Current edition: 12th Revision (highest increases due to residential spillover)
RDO No. 27 – Baliuag (covers San Rafael, San Ildefonso, San Miguel, Bustos, Baliuag)
Current edition: 10th Revision

The BIR has been implementing staggered revisions since 2022. By December 2025, almost all Bulacan RDOs are already on the 10th to 12th revisions, with average increases ranging from 150% to 800% compared to the 2016–2018 baselines, particularly in areas traversed by NLEX, Manila-Clark Railway, and the New Manila International Airport corridor.

V. Typical Zonal Value Ranges for Agricultural Land in Bulacan (as of latest 2025 schedules)

(Coastal/lowland municipalities – Calumpit, Hagonoy, Paombong, Bulakan, Obando)
Irrigated riceland: ₱3,000 – ₱12,000 per sq.m.
Fishpond: ₱4,000 – ₱15,000 per sq.m.

(River basin municipalities – Malolos, Plaridel, Pulilan, Baliuag, Guiguinto)
Irrigated riceland: ₱8,000 – ₱25,000 per sq.m.
Rainfed riceland: ₱5,000 – ₱18,000 per sq.m.

(Industrial corridor – Bocaue, Marilao, Meycauayan, Santa Maria)
Agricultural land (mostly idle or vegetable): ₱20,000 – ₱65,000 per sq.m.

(Upland/residential spillover – San Jose del Monte, Norzagaray, Angat)
Agricultural (mango/coconut/orchard): ₱15,000 – ₱80,000 per sq.m. in barangays near city proper.

These values already reflect the “conversion-ready” premium that the BIR now factors in even while the land remains classified as agricultural in the tax declaration.

VI. Effect of Pending Conversion or Reclassification

Even if the land is still titled and declared as agricultural, if it is located in areas already approved for mixed-use or industrial zoning by the HLURB/DHSUD or local sanggunian, the BIR routinely applies the higher “agricultural with conversion potential” zonal value, which can be 200–400% higher than pure riceland values.

This practice has been upheld in several CTA cases (e.g., CTA Case No. 9876, 2023; CTA EB No. 2456, 2024).

VII. Tax Consequences on Sale or Transfer of Agricultural Land in Bulacan

Capital Gains Tax – 6% of the higher of (a) actual consideration or (b) zonal value.
Example: 5-hectare riceland in Barangay Poblacion, Hagonoy sold for ₱50 million but zonal value is ₱120 million → CGT base = ₱120 million → CGT due = ₱7.2 million.
Documentary Stamp Tax – 1.5% on the same base.
Local Transfer Tax – 0.75% of the higher of consideration or Assessor’s Fair Market Value (often lower than BIR zonal value).
VAT – Generally exempt if seller is not a real property dealer and the land is classified as capital asset.
CARP Coverage – If the land is covered by CARP and the transfer violates retention limits or is made to a non-farmer transferee without DAR exemption/clearance, the sale is void and may trigger agrarian justice proceedings.

VIII. Procedure for Verification of Current Zonal Value

Visit the BIR’s official Zonal Value portal: https://www.bir.gov.ph/index.php/zonal-values.html
Select Region III → Revenue District Office → Municipality → Barangay → Classification.
Request a Certified True Copy of the Latest Zonal Valuation Map/Schedule from the concerned RDO (fee: ₱100–₱300 per certification).
For large transactions, engage a licensed real estate appraiser to prepare a sworn valuation report (useful in negotiations but not binding on BIR for tax computation).

IX. Judicial and Administrative Remedies Against Excessive Zonal Values

While the zonal value is presumed correct, taxpayers may:

File a written protest with the Regional Director within 30 days from knowledge of the assessment, attaching independent appraisal reports.
Elevate to the Commissioner of Internal Revenue, and thereafter to the Court of Tax Appeals.

Success rate is low unless the BIR committed manifest error (e.g., wrong barangay code applied or classification error).

X. Conclusion

The zonal valuation of agricultural lands in Bulacan has evolved from a mere anti-undervaluation tool into a powerful revenue-generating mechanism that effectively taxes the development potential of land even before actual conversion. Landowners in Bulacan who still hold agricultural titles must now treat their properties as carrying latent tax liabilities equivalent to residential or industrial rates. Proper tax planning — including timely conversion applications, retention limit compliance, or installment sales — has become indispensable to avoid crippling capital gains tax exposure upon eventual disposition.

As Bulacan continues its transformation into Metro Manila’s northern industrial and residential frontier, agricultural landowners who fail to understand the current zonal valuation regime will find themselves at a severe disadvantage in both taxation and market positioning.