Philippines: e-Submission of Employee Alphalist Now Required

18 February 2014
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On December 17, 2013, the Bureau of Internal Revenue (BIR) issued Revenue Regulation (RR) No. 1-2014 requiring all employers/withholding agents, regardless of their number of employees and payees, or whether the employees/payees are exempt, to submit an alphabetical list (alphalist)* of employees and list of payees on income payments subject to creditable and final withholding taxes to be attached as integral part of the Annual Information Returns (BIR Form No. 1604CF/1604E) and Monthly Remittance Returns (BIR Form No. 1601C, etc.).

Per the announcement, “The manual submission of the alphabetical lists containing less than ten (10) employees/payees by withholding agents under Annual Information Returns BIR Form No. 1604CF and BIR No. 1604E shall be immediately discontinued beginning January 31, 2014 and March 1, 2014, respectively, and every year thereafter.”

Under this procedural change, the alphalist must be submitted

  • As attachment in the Electronic Filing and Payment System (eFPS);
  • Through electronic submission using the BIR’s website; and
  • Through email at dedicated BIR addresses using the prescribed CSV data file format, the details of which will be issued in a separate revenue issuance.

“In cases where any withholding agent does not have its own internet facility or unavailability of commercial establishments with internet connection within the location of the withholding agent, the alphalist prescribed herein may be electronically mailed (e-mail) thru the e-lounge facility of the nearest revenue district office or revenue region of the BIR.”

Interestingly, until this change, submission via CD and even floppy disk was permitted. It’s also important to note that “The submission of the herein prescribed alphalist where the income payments and taxes withheld are lumped into one single amount (e.g. “Various employees”, “Various payees”, “PCD nominees”, “Others”, etc.) shall not be allowed. The submission thereof, including any alphalist that that does not conform with the prescribed format thereby resulting to the unsuccessful uploading into the BIR system shall be deemed not as received and shall not qualify as a deductible expense for income tax purposes.” Penalties for submission failures are rather steep, particularly given the very tight implementation turnaround for the revised submission process.

For further details, full filing procedures, and penalties for failure to file properly, please see this helpful January 29, 2014 government memorandum: RMC 5-2014.

*An “alphalist” contains the following information:

  • Month
  • TIN of withholding agent
  • Name of Withholding Agent
  • TIN of Payee
  • ATC
  • Nature of Payment
  • Name of Payee
  • Amount of Payment
  • Tax Rate
  • Tax Required to be Withheld