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.
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