In accordance with Section 3 of Revenue Regulations No. 13-2024 for the extension in the filing of tax returns and payment of the corresponding taxes due thereon, including submission of affected attachments, this Circular is being issued in order to provide assistance to taxpayers who were affected by recent earthquake within the jurisdiction of South Central Mindanao Region, which caused substantial damage to business establishments, government offices, and vital infrastructure, thereby disrupting normal business operations and limiting access to accounting records.
Relative thereto, the Bureau of Internal Revenue (BIR) is hereby extending the deadline for the filing of tax returns and payment of the corresponding taxes due thereon, including submission of required attachments to provide ample time for taxpayers and BIR Personnel under the following Revenue District Offices (RDOs) to comply with the statutory tax deadlines:
Accordingly, this Circular shall extend the statutory deadlines for submission and/or filing of the following attachments and/or tax returns, as well as the payment of the corresponding taxes due, as specified below:
Taxpayers covered by this Circular shall not be subjected to the imposition of penalties, surcharges, and interest, provided that the concerned tax returns, payments, and submissions are made with the extended period.
Further, if the extended due dates fall on a holiday or non-working day, the filing, payment and submission contemplated herein shall be made on the next working day.
In line with Republic Act No. 11976, otherwise known as “Ease of Paying Taxes (EOPT) Act”, as implemented by Revenue Regulations (RR) Nos 3-2024 and 7-2024, this circular is being issued to amend Revenue Memorandum Circular (RMC) No. 116-2024 re: Inclusion of Lifeline Subsidy and Green Energy Auction Allowance as government mandated charges not subject to Output Tax and Creditable Withholding Tax on VAT and Income. Accordingly, Q&A No. 3 of RMC No. 116-2024 is hereby amended to read as follows:
“Q3: Are the government mandated charges shall nor be subject to Output Tax and consequently on Creditable Withholding on VAT and Income?
A3: The following mandated government charges shall not be subject to Output Tax and Creditable Withholding Tax on VAT and Income.
All other revenue memorandum circulars and rulings inconsistent herewith are hereby amended, modified or repealed accordingly.
This Revenue Memorandum Circular (RMC) is issued to further clarify Revenue Regulations (RR) No. 3-2025 and address certain issues pertaining to the implementation of the Value-Added Tax (VAT) on Digital Sevice.
Q1: If a nonresident digital service provider (NRDSP) supplies or delivers digital services to Philippine consumers and such digital services qualify to register with the BIR and file VAT-exemption, is the NRDSP still required to register with the Bureau of Internal Revenue (BIR) in accordance with RR No. 3-2025?
A1: Yes. If the NRDSP supplies digital services to Philippine consumers and such services are entitled to VAT exemption, it shall be required to register with the BIR and file VAT returns. Of the sales of the NRDSP are VAT-exempt, these shall be indicated as VAT-exempt sales in the VAT Returns.
Q2: In a cross-boarder cost-sharing arrangements involving (i) foreign digital service provider, (ii) a foreign affiliate contracts for and/or pays for such digital services under the cost-sharing arrangement, and (iii) a Philippine subsidiary that ultimately consumes the digital service, such transaction is subject to VAT under RR No. 3-2025 even if the payment is through a cost-sharing agreement. The Philippine subsidiary will be responsible for withholding and remitting the VAT as a Business-to-Business (B2B) transaction.
A2: a. Generally, the foreign supplier of the digital service is considered as the NRDSP. However, since the NRDSP is directly contracting with the foreign affiliate and has no direct transaction with the Philippine subsidiary, it shall not be required to register with BIR, unless it is also supplying digital service transaction subject to VAT to other Philippine consumers.
In this case, since the foreign affiliate is the one directly transacting with the foreign supplier, on one hand, and Philippine subsidiary, on the other, it shall be deemed as the NRDSP and shall be required to register with the BIR if it has control on the key aspects of the supply of digital services to its Philippine subsidiary, as follows:
b. In any case, since this is a B2B transaction, the Philippine subsidiary, under the reverse charge mechanism, shall be liable for filing the required VAT return and withholding and remitting, shall be liable for filing the required VAT return and withholding and remitting the twelve percent (12%) VAT due on the cost of the digital service charge to it, as may be evidenced by the billing or invoice issued by the foreign affiliate.
Q3: RGA Corporation, a Philippine VAT-registered property management company, offers end-to-end short-term rental solutions property owners (condominium owners, resort operators and shall hotels) across the Philippines. It manages the entire rental process including guest communication, housekeeping and maintenance, and net income sharing among the property owners. RGA Corporation subscribes to various NRDSP online booking platforms to facilitate reservations. These NRDSP platforms online booking platforms to faciliate reservations. These NRDSP platforms charge RGA Corporation a fixed listing or subscription fee for access and visibility, and additional commission fee/service for each successful booking.
A3: a. Yes. The subscription fees and commission fees/service fees constitute payment for a digital service supplied by a NRDSP, this, RGA Corporation, being an entity engaged in business in the Philippines, is liable to withhold the VAT and remit the same to the BIR under the reverse charge mechanism for a B2B transaction. RGA Corporation shall remit the VAT using the BIR Form 1600-VT within ten (10) days following the end of the month the withholding was made.
b. No. The NRDSP online booking platforms are only liable for the 12% VAT on digital services attributable to the subscription fees and commission fees/service fees earned from listing/ subscription and bookings and not on the full amount received since it is the portion that qualifies as digital service as defined in RR No. 3-2025. The service fees were earned through the use of the internet for facilitating the booking which is essentially automated.
Q4: In December 2024, RBB Company paid for a one-year cloud subscription for the period covering December 2024 to November 2025. The invoice issued for the subscription did not include the twelve percent (12%) VAT. Is RBB Company still liable to withhold and remit the VAT pursuant to RR No. 3-2025 despite the non-indication of VAT in the issued invoice?
A4: Yes. In a B2B transaction, the buyer of digital services is liable to withhold the VAT and remit the same to the BIR under the reverse charge mechanism. Since the VAT on Digital Service Provider (DSP) became effective only on June 2, 2025, RBB Company must compute and remit the twelve percent (12%) VAT applicable to the remaining months of the subscription period covering June to November 2025, in accordance with Section 6(B) of RR No. 03-2025.
Q5: MRA SG, a corporation organized and existing under the laws of Singapore, billed and issued an inoice to Multi-Media Agency, Inc., a Philippine-based corporation, for the online advertisements. Subsequently, Multi-Media Agency, Inc. charged and issued an invoice, without any mark-up, to a Malaysia-based client that is not registered in the Philippines. The target audience of the online advertisements is in Malaysia.
A5: a. Yes. The digital service is subject to 12% VAT in the Philippines. Under Republic Act (RA) No. 12023 and RR No. 3-2025, the 12% VAT applies to digital services supplied to a consumer located in the Philippines, regardless of whether the service provider is a resident or nonresident. In this case, since the user, procurer and payor of the online advertisement is a Philippine-based entity, the same is subject to VAT regardless of the location of the audience.
b. Under the reverse charge mechanism, Multi- Media Agency, Inc., being an entity engaged in business in the Philippines, is required to withhold and remit the 12% VAT to the BIR as a B2B transaction.
c. Yes. It is subject to VAT as zero rate since its services are consumed by clients located abroad, provided that the same are paid for in acceptable foreign currency and accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP).
Q6: Is a nonresident corporation engaged solely in facilitating real-time fund transfers between parties to a digital transaction and not operating as an e-commerce platform, subject to the 12% VAT on the service fee for the digital services of facilitating real-time fund transfers under RA No. 12023 and its implementing rules under RR No. 3-2025?
A6: Yes. The nonresident corporation is subject to the 12% VAT imposed on the digital service if it collects service fees to a client located in the Philippines for the use of its services. The 12% VAT shall be based on the amount of service fee collected.
Q7: In relation to Question 21 of RMC No. 47-2025 in which the payments for digital services are made directly to the NRDSP rather than the e-marketplace, in a scenario where the e-marketplace collects the VAT payments in advance on behalf of its online sellers on a pre-collected or advance basis based on stock availability, is the e-marketplace considered a “digital service provider” or “e-marketplace” for VAT compliance purposes under RA No. 12023 and RR No. 3-2025? Is it required to file BIR Form 2550-DS and remit the 12% VAT on all business-to-consumer (B2C) transaction facilitated through its digital interface, despite not receiving the actual payments directly?
A7: Yes. The e-marketplace may still be considered a digital service provider or e-marketplace for VAT compliance purposes in the Philippines under RA No. 12023 and RR No. 3-2025, even if it does nor directly receive payments for the digital services sold through its platform since it collects the VAT payments in advance. In such case, the e-marketplace that collects VAT on the covered B2C transactions.
Q8: ABC Corporation, a NRDSP based in Singapore, is delivering digital services to consumers in the Philippines. It was issued a Certificate of Entitlement to Treaty Benefits (COE) pursuant to the Double Taxation Agreement (DTA) between the Philippines and Singapore. Is the digital service supplied by ABC Corporation subject to VAT?
A8: Yes. ABC Corporation is subject to VAT on Digital Service. Tax benefits, either preferential tax rate or tax exemption, under a tax treaty cover only Income Tax. However, the digital service may be VAT zero-rated or VAT-Exempt not under the DTA but pursuant to Sections 108,109, and 295 of the National Internal Revenue Code of 1997, as amended.
In addition to the obligation to deduct and remit the withholding taxes to the Bureau of Internal Revenue (BIR), pursuant to the provisions of Revenue Regulations (RR) No. 2-98, as amended by RR No. 11-2018, all withholding agents are required to submit Alphabetical List of Employees/Payees from Whom Taxes Where Withheld (alphalist) to the BIR, as an attachment to the withholding tax returns. Hence, its deadline of submission is the same with the deadline of submission of the said returns.
The type of alphalist to be submitted depends on the specific withholding tax return and irs corresponding deadline, as follows:
Since the alphalist is an attachment and therefore a part of the withholding tax return, the submission of the alphalist is likewise an obligation of the withholding agent. Failure to submit the alphalist constitutes a violation of BIR regulations and is subject to the corresponding penalty.
The recently issued RR No. 16 – 2023, as amended by RR No. 5-2025, identified electronic marketplace (e-marketplace) operators and digital financial services providers (DFSPs) as withholding agents required to remit one-half percent (1/2%) of their gross remittances to sellers of goods and services. However, BIR records show that many of those entities have not complied with this requirement.
Accordingly, this Circular is hereby issued as a reminder to all withholding agents, particularly e-marketplace operators and DFSPs, to strictly comply with the submission of alphalist through the BIR eSubmission facility as prescribed under RR No. 1-2014 to avoid unnecessary penalties.
This Circular supplements Revenue Memorandum Circular (RMC) No. 86-2023 by recognizing the updated composition of securities from the PSE bi-annual index rebalancing, as transmitted by the SEC.
The SEC, through its letter dated 29 January 2026 (Annex “B”) , informed the Bureau of Internal Revenue (BIR) of the official results of the PSE bi-annual rebalancing of the PSE Index (PSEi) and Dividend Yield Index which took effect on 02 February 2026, pursuant to Section 3 of SEC Memorandum Circular (MC) No. 7, Series of 2022, otherwise known as the Rules on Qualified and/r Eligible PERA Investments.
In view thereof, and for the purposes of administering tax incentives under Republic Act No. 9505, otherwise known as “PERA Act of 2008”, and its Implementing Rules and Regulations, the following clarifications are hereby issued:
Nothing in this Circular shall be construed as amending or revoking tax rules, but merely supplementing and clarifying the same in light of the SEC Notice.
In line with the Bureau of Internal Revenue’s (BIR) continuing efforts to modernize tax administation, enhance taxpayer services, and promote ease of doing business, this Circular is issued to announce the availability of the Taxpayer Portal and its pilot implementation covering taxpayers registered under the offices/divisions of the BIR’s Large Taxpayers Service (LTS).
The Taxpayer Portal is secured digital platform that provides taxpayers with a single-view online access to their tax information. Through a centralized taxpayer profile, taxpayers can payments, and receive timely system-generated reminders for tax returns, track taxpayments, and receive timely system- generated reminders for tax return filing and payment obligations. With the said features the need for manual follow ups and in-person visits to BIR offices will be reduced.
As part of the pilot implementation, taxpayers registered under the LTS may enroll in the Taxpayer Portal and use the following system functionalities:
The pilot implementation of the Taxpayer Portal to taxpayers registered under the LTS is intended to support the gradual rollout of the system to other types of taxpayers by ensuring its operational readiness prior to wider development.
For enrollment assistance and technical concerns regarding the use of the Taxpayer Portal, or issues regarding the accuracy of taxpayer records reflected in the taxpayer account, taxpayers are advised to coordinate directly with their concerned Large Taxpayers Office/ Division where they are registered.
All internal revenue official and employees are hereby enjoined to give this Circular as wide a publicity as possible.
Prescribing Simplified and Streamlined Guidelines and Procedures in the Closure and/or Cancellation of Business Registration with the Bureau of Internal Revenue
SECTION 1. Purpose. – Pursuant to Section 5(J) of Revenue Regulations No. 7-2024 and Revenue Memorandum Circular No. 91-2024, implementing Republic Act (RA ) No. 11976 standardize, and streamline the guidelines and procedures in the processing of applications for closure and/or cancellation of taxpayer’s business registration with the Bureau of Internal Revenue (BIR).
SECTION 2. Coverage. – This Circular shall apply to all business taxpayers registered with the BIR, whether domestic or foreign, resident or non-resident, that have permanently ceased business operations or have otherwise become subject to closure or cancellation of business registration, including but not limited to the following persons:
SECTION 3. Modes and Venue of Filing of Application for Closure and/or Cancellation of Business Registration. – The application for closure and/or cancellation of business registration, together with the required documents, shall be submitted to the concerned Revenue District Office (RDO) where the taxpayer’s Head or Branch Office is registered, either electronically, by sending the documents using the taxpayer’s official email address, or through the BIR’s Portal, Online Registration and Update System (ORUS), or manually, by personally submitting the documents to the concerned RDO. Provided that, documentary requirements, under Items 3 and 4 in Section 4 hereof shall be submitted manually.
SECTION 4. Documentary Requirements. – Only the following documents shall be submitted for the closure and/or cancellation of taxpayer’s business registration with the BIR:
SECTION 5. Filing and Payment of Final Tax Returns. – The taxpayer shall file all final or short-period tax returns covering the period from the beginning of the taxable year up to the date of closure for all applicable tax types and pay the corresponding taxes due thereon. For periods during which there was no business activity, the taxpayer shall file zero returns.
SECTION 6. Effect of Submission of Documentary Requirements and Completion of the Closure and/or Cancellation of Business Registration Process. – The registration of the taxpayer shall be cancelled upon mere filing and submission of the complete requirements enumerated under Section 4 hereof, either electronically or manually, with the RDO where the taxpayer is registered. Penalties for non-filing of returns shall not accrue after the submission of the required documentary requirements under Section 4 hereof. For this purpose, the taxpayer’s registered form types shall be placed under “deregistered” upon submission of the complete documentary requirements to ensure that no open cases will be generated.
For micro taxpayers or taxapyers, whose gross sales for the immediately preceding year do not exceed Three Million Pesos (P3,000,000.00) or whose gross assets upon retirement do not exceed Eight Million Pesos (P8,000,000.00), the Tax Clearance shall be issued within three (3) working days from the date of submission of the application with complete documentary requirements, if the taxpayer has no open cases or outstanding liabilities, or within (3) working days from the date of submission of the application with complete documentary requirements and payment of any outstanding tax liabilities, including penalties. Thereafter, the business name registration status of the taxpayer shall be updated to “Closed” in the BIR registration database. Micro taxpayers shall not be subject to mandatory audit for closure and/or cancellation of business registration.
The updating of the registration status to “Closed” shall complete the closure or business registration cancellation process for individual taxpayers. For non-individual taxpayers, the TIN shall subsequently be cancelled to comlere the closure or business registration cancellation process.
The taxpayers with pending audit under an existing Letter of Authority, or taxpayers whose gross sales for the immediately preceding year exceed Three Million Pesos (P3,000,000.00) or whose gross assets upon reitrement exceed Eight Million Pesos (P8,000,000.00), the Tax Clearance shall be issued and the closure or business registration cancellation process completed, only after the termination of the conduct of audit.
SECTION 7. Effect of Failure to Apply for Closure and/or Cancellation of Business Registration. – Taxpayers who cease business operations without submitting the documentary requirements for the closure and/or cancellation of their business registration with the BIR, prescribed under Section 4 hereof, shall continue to be liable for all their tax obligations, including the filing of tax returns and payment of taxes, including penalties, until closure and/or cancellation of business registration is completed with the BIR, as provided under Section 6 hereof.
SECTION 8. Repealing Clause. – All existing rules which are inconsistent with the provision of this Circular are hereby amended, modified or repealed accordingly.
SECTION 9. Effectivity.– This Circular shall take effect immediately.
All internal revenue officials, employees, and others concerned are hereby enjoined to give this Circular as wide a publicity as possible.
This Circular is issued to prescibe the extension of filing of the 2025 Audited Financial Statements (AFS) and Other Attachments, and guidelines to ensure uniform handling by all concerned offices of the issues encountered by taxpayers in the submission of AFS and other attachments through the Electronic Audited Financial Statements (eAFS)/ Submission Facility during the recently concluded Annual Income Tax Return filing period:
This Circular is issued to clarify the requirement of the submission of the Certificate of Entitlement to Tax Incentives (CETI) as a mandatory attachment to the Annual Income Tax Return (AITR) of Registered Business Enterprise (RBE) taxpayers.
It is hereby clarified that Revenue Memorandum Circular (RMC) No. 20-2026 did not amend nor repeal existing requirements relating to the submission of the CETI by RBE taxpayers. The list of attachments to the AITR indicated in RMC No. 20-2026 is similar to those prescribed under the following prior issuances: (1) RMC No. 34-2025; (2) RMC No. 51-2024; and (3) RMC No. 44-2023. All of the above issuances were issued in reference to and consistent with the provisions under RMC No. 28-2022, which governs the submission of CETI in support of the availment of Income Tax incentives.
Pursuant to the provisions of Section 4 under Rule 8 of the Implementing Rules and Regulations of Republic Act (RA) No. 11534 (CREATE Act), as further implemented by RA No. 12066 (CREATE MORE Act), RBEs duly registered with Investment Promotion Agencies are mandated to attach the CETI to their AITR filed with this Bureau. The requirement to submit the CETI remains enforceable and is not dependent on any express enumeration, and continues to apply notwithstanding the non-inclusion of the CETI in subsequent circulars providing general lists of AITR attachments.
In accordance with the existing rules and regularions, the CETI shall continue to form part of the mandatory attachments to the AITR for RBE taxpayers availing of Income Tax Incentives. The non-inclusion of the CETI in the illustrative list of attachments under RMC No. 20-2026 shall not be construed as a waiver or removal of the said requirement.
Pursuant to Section 236 of the National Internal Revenue Code of 1997, as amended (Tax Code) and its Implementing Rules and Regulations under Section 5 of Revenue Regulations (RR) No. 7-2026 and Section 5 of RR No. 15-2024, every person subject to any internal revenue tax is required to register with the Revenue District Office of the Bureau of Internal Revenue on or before the commencement of business, before payment of any tax due, or before or upon filing of any applicable tax return, statement or declaration as mandated by the Tax Code.
Moreover, Section 5(F) of RR No. 7-2024 provides for the issuance of Certificate of Registration (COR) or Electronic Certificate of Registration (eCOR) to each Head Office, Branch and Facility within the period of/time prescribed in the BIR Citizen’s Charter, upon submission of complete documentary requirements.
Section 5(G) of RR No. 7-2024 and Section 6 of RR No. 15-2024 require all persons subject to the provisions of Section 5(C) and (D) of RR No. 7-2024 (persons engaged in business or practice of profession) to post the COR or eCOR at the place where the business is conducted and at each branch and/or facility in a manner that is clearly visible to the public.
In addition, Section 5(H) of RR No. 7-2024 and Section 7 of RR No. 15-2024 further require the posting of proof of registration by sellers/merchants on their online websites, e-commerce or e-marketplace pages, and other platforms. In this regard, online businesses, sellers or merchants and service providers operating a business or with sales transactions through a website, social media or any digital or electronic means shall display conspicuously the electronic copy of their BIR COR/eCOR on their website, account or profile pages of the e-commerce platform or mobile application, where it is clearly visible and easily accessible to buyers or customers.
In line with the foregoing provisions, this Circular is hereby issued to implement the requirement under Section 5(H) of RR No. 7-2024 and Section 7 of RR No. 15-2024 on the posting of proof of registration on online websites, e-commerce or e-marketplace seller/merchant’s page, and other platforms. This requirement applies not only to online sellers of goods but also to persons engaged in providing services through digital or electronic means or with online presence, including but not limited to professionals or persons offering their services through online website, e-commerce platforms or mobile applications, bloggers, vloggers, live streamers, content creators, influencers, and individuals earning through online views, advertisements, affiliate commissions, brand sponsorships, or similar monetized digital activities.
To address taxpayers’ concerns over the online disclosure of sensitive information contained in their COR/eCOR, the BIR shall issue a BIR Registration Seal Badge (Annex A) to be displayed on the seller’s/content creator’s/online influencer’s website, online page/platforms, e-commerce shop, in lieu of the BIR COR/eCOR.
Policies and Guidelines
3. Both the BIR COR/eCOR and BIR Registration Seal Badge shall contain a Quick Response (QR) Code that can be verified online by scanning the QR Code using any mobile application or QR Code scanner. The QR Code will enable verification of the authenticity of the BIR COR/eCOR and validity of taxpayer’s business registration with the BIR.
4. Taxpayers are not required to replace their existing BIR COR/eCOR that does not contain a QR Code; however, they are encouraged to update or replace the same for the purposes of securing a BIR Registration Seal Badge. Taxpayers who are required to post online a proof of their BIR registration shall secure a BIR Registration Seal Badge with the Bureau’s Revenue District Office where they are registered by updating their registration information, or secure it online via ORUS by updating their registration information and paying the P30.00 Loose Documentary Stamp Tax (DST).
5. The BIR Regisrtation Seal Badge shall be posted on the following, including but not limited to:
6. To ensure consistent and proper online display of the BIR Registration Seal Badge on websites, mobile applications, online shops and e-commerce platforms, the following guidelines shall apply:
Government agencies, banks and financial institutions, e-commerce platforms and other relying parties may verify the validity of the BIR COR/eCOR/BIR Registration Seal Badge and taxpayer’s current registration with the BIR by scanning the QR Code on the document. When the QR Code is scanned, relying parties must ensure that the URL displayed is the official BIR verification domain or BIR link before relying on the result of verification of validity of the BIR COR/eCOR/BIR Registration Seal Badge.
The BIR COR/eCOR with QR Code and BIR Registration Seal Badge shall be available upon the issuance and publlication of this Circular on the BIR Website. A Taxpayer’s User Guide on how to generate and secure the BIR Registration Seal Badge through ORUS is provided in Annex C.
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