Before the first sale: BIR registration, books of accounts and the authority to print
SEC registration gives the company legal existence. Before it starts trading, it still needs its BIR primary registration and a set of secondary registrations, and the books of accounts and the authority to print are the two most often left too late.
The BIR's registration requirements page splits registration into two layers:
- Primary registration: the Taxpayer Identification Number (TIN) and registration updates. Corporations and partnerships register on BIR Form 1903. The BIR has five registration forms in all: 1901 for self-employed and mixed-income individuals, 1902 for individuals earning purely compensation income, 1903 for corporations and partnerships, 1904 for one-time taxpayers, and 1905 for updating registration information. What the TIN is and why a taxpayer holds only one is covered in the Philippine TIN explained.
- Secondary registration: registration of books of accounts; the Authority to Print (ATP) receipts and invoices; authority to use a Computerized Accounting System (CAS) or its components, or loose-leaf books; and the permit to use cash register machines (CRM) or point-of-sale (POS) machines.
Why books must be registered. The BIR's secondary registration page says all corporations, companies, partnerships or persons required by law to pay internal revenue taxes must keep a journal and a ledger, or their equivalents such as subsidiary ledgers or simplified books. There are two ways to register them:
- Online, through the BIR's Online Registration and Update System (ORUS). When registration succeeds, the system generates a "QR Stamp" that the taxpayer pastes on the first page of the books.
- Manually, with BIR Form 1905 plus attachments that depend on the type of books: a new set of permanently bound books for manual books; for loose-leaf books, the permit to use them, the bound loose-leaf books and an affidavit on the completeness of the entries and the number of leaves used; for computerized books, the acknowledgement certificate or permit to use the CAS or computerized books where applicable, a storage device holding the electronic books in Standard Audit File (SAF) format with a transmittal letter describing its contents, and an affidavit on the completeness and accuracy of the records.
Choosing between manual, loose-leaf and computerized books is covered in books of accounts registration. One point of timing matters here: the BIR states that a computerized accounting system must be registered before it is actually used. Installing the software first and registering it later is one of the most common sequencing mistakes new companies make.
If a representative files on the company's behalf, the BIR asks for a board resolution or secretary's certificate (a written resolution for a one person corporation) naming the representative and the purpose, plus a copy of a government-issued ID of one signatory and of the representative. How the SEC, BIR and city hall steps fit together is set out in registering a company in the Philippines.
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Invoices and supporting records: what the books are built from
Get the authority to print on or before the first day of business. After that, an invoice for every sale and a document for every purchase are what make the books balance and the returns correct.
The BIR's secondary registration page says every person engaged in business must secure an Authority to Print from the BIR before a printer can print its receipts or sales or commercial invoices, and that the application is due on or before the commencement of business. Businesses that issue invoices through cash register or POS machines need a separate permit to use them.
Invoicing rules have changed more than once in recent years. After the Ease of Paying Taxes Act (Republic Act No. 11976, known as EOPT) took effect, the roles of invoices and receipts were adjusted; what changed and what to do with old receipts is covered in official receipts and invoicing rules. Who must connect to the BIR's Electronic Invoicing System (EIS), and by when, is in BIR e-invoicing. This guide does not repeat either.
For bookkeeping purposes, keep supporting documents in three groups:
- Sales: invoice copies or system records in sequence, including cancelled invoices.
- Purchases: supplier invoices. For a VAT-registered company these support the input tax claimed on the quarterly VAT return.
- Withholding certificates: when a customer withholds tax from a payment to you, it should give you BIR Form 2307, the Certificate of Creditable Tax Withheld at Source. The BIR lists it, where applicable, as an attachment to the quarterly VAT return and to the quarterly and annual income tax returns. Without the 2307s, tax already withheld from you is hard to credit.
The reverse also applies. When the company pays suppliers, landlords or professionals, it is often the withholding agent and must withhold and issue the 2307 itself; see expanded withholding tax.
The BIR also has specific regulations on preserving books of accounts and accounting records (Revenue Regulations No. 17-2013) and on keeping and submitting electronic records (Revenue Regulations No. 9-2009). Retention periods and formats follow the BIR's current rules.
Day to day, problems tend to start in the same places: the owner's personal account mixed with the company account, cash sales not invoiced on the spot, purchases backed by a receipt but no invoice, and tax withheld without a 2307 being issued. Any one of these turns month-end bookkeeping into guesswork, and the quarterly returns stop reconciling. For cash-heavy small businesses where paperwork tends to go missing, the usual weak points are described in cash and books risks for small shops.
What a Philippine company files every month
Every month a company keeps its books and remits the taxes it has withheld. VAT is now filed quarterly by law, and a monthly VAT return is optional.
Start with who is responsible. The BIR's withholding tax page says the duty to withhold falls on individuals engaged in business or a profession, on non-individuals such as corporations, associations, partnerships and cooperatives whether or not they are engaged in business, and on government agencies. A withholding agent is any person or entity "in control of the payment subject to withholding tax" and therefore required to deduct and remit the tax. Once a company pays wages, or makes certain payments to others, it is a withholding agent: the returns are filed in the company's name and the liability is the company's.
The usual monthly items:
| Item | Form | Who | Read next |
|---|---|---|---|
| Record the month's transactions in the journal and ledger | Registered books | Every company | books registration |
| Remit tax withheld on employees' compensation | BIR Form 1601-C | Companies with employees | 1601-C and alphalist |
| Remit expanded withholding tax monthly | BIR Form 0619-E | Companies paying suppliers, landlords, professionals and others subject to withholding | expanded withholding tax |
| Remit final withholding tax monthly | BIR Form 0619-F | Companies making payments subject to final withholding | Current BIR rules |
| Monthly VAT return (optional) | BIR Form 2550M | VAT-registered companies that choose monthly filing | VAT and percentage tax filing |
On the monthly VAT return, the BIR's VAT page cites Revenue Memorandum Circular No. 52-2023: the Tax Code now requires VAT to be filed and paid quarterly, but VAT-registered persons may continue to file and pay monthly on Form 2550M. Switching between monthly and quarterly filing does not attract penalties, but the quarterly return, Form 2550Q, must still be filed within the period set by the Tax Code.
Employers also carry duties that run through the year. The BIR lists them: withhold in the prescribed manner, remit by the due dates, carry out the year-end adjustment, refund excess withholding and issue Form 2316 to employees. When new staff join, the employer also submits their registration form (BIR Form 1902 or 1905) to the RDO within the prescribed period. The payroll cycle, including the year-end recomputation, is covered in the 1601-C guide in the table.
So the precise answer to "what does a Philippine company file every month" is: mostly withholding returns. Business tax (VAT or percentage tax) is quarterly, and income tax is paid quarterly and settled annually.
Exact due dates for every monthly, quarterly and annual item, including the staggered dates for electronic filers grouped by industry, are kept in one place: the Philippine tax calendar. They are not repeated here, so the two pages cannot drift apart.
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Quarterly and annual returns, including periods with no sales
Each quarter a company files a business tax return (VAT or percentage tax, not both), a quarterly income tax return and withholding summaries. Each year it files the annual income tax return, annual withholding information returns and employee certificates. Returns are due even when no tax is payable.
Quarterly
- Business tax, one or the other. A VAT-registered company files BIR Form 2550Q, one consolidated return covering the head office and all branches for every line of business subject to VAT, and the BIR also requires VAT taxpayers to submit quarterly Summary Lists of Sales and Purchases. A company that is not VAT-registered and whose annual gross sales stay under the VAT threshold generally files BIR Form 2551Q for percentage tax. The threshold follows the BIR's current rules; how to judge it is covered in the VAT registration threshold.
- Quarterly income tax. Corporations and partnerships file BIR Form 1702Q, attaching 2307 certificates where applicable.
- Quarterly withholding summaries. Expanded withholding goes on BIR Form 1601-EQ, and final withholding on Form 1601-FQ.
Annual
- Annual income tax: corporations and partnerships file BIR Form 1702. The BIR's income tax page says companies whose gross annual sales, earnings or receipts exceed the statutory threshold attach balance sheets, profit and loss statements and related schedules certified by an independent CPA; those below it may attach the Account Information Form (BIR Form 1702 AIF) instead.
- Annual withholding information returns: BIR Forms 1604-C (compensation), 1604-E (expanded) and 1604-F (final), each with the alphabetical list of employees or payees.
- Employee certificates: BIR Form 2316 goes to each employee, and a duplicate is submitted to the company's Revenue District Office (RDO). Qualifying employees can rely on the employer's 1604-C in place of their own annual return.
No sales still means filing. The BIR's VAT page sets out separate procedures for returns with a payment and returns without one, and the latter still have to be filed. The BIR's penalties page also lists compromise penalties specifically for late returns with no tax due. A newly formed company with no revenue yet still has filing obligations, and that "nothing to report" stretch is where many missed filings begin: nobody remembers to file, and a few quarters later every period turns out to be late.
A practical way to stay on top of it is to split the quarterly and annual items into three checklists: business and income tax for the accountant, withholding returns for whoever runs payroll and payments, and the annual summaries and employee certificates for a single review at the start of each year. How the three layers stack up, and which months are busiest, is covered in the BIR filing calendar for companies.
Audited financial statements and SEC reports: BIR first, then eFAST
The annual financial statements go to the BIR first; the company then files them with the SEC through eFAST, with proof of BIR receipt attached. The General Information Sheet is filed separately after the annual stockholders' meeting.
SEC Memorandum Circular No. 9, series of 2026 (full text), spells out the sequence:
- BIR before SEC. Financial statements filed with the SEC, other than consolidated statements, must bear the BIR's "received" stamp. Companies that used the BIR's eAFS system attach the system-generated transaction reference number or confirmation receipt instead.
- Who must be audited. Under Revised SRC Rule 68, the circular lists the entities that must submit annual audited financial statements: stock and non-stock corporations whose total assets or total liabilities exceed the prescribed threshold, and branch offices, representative offices and regional operating headquarters of foreign corporations that reach their own thresholds. The amounts follow the SEC's current rules. Corporations below the threshold may file with a sworn Statement of Management's Responsibility, signed by the chairman, president or chief executive officer and the treasurer or chief financial officer, or, for a one person corporation, by the president and treasurer. Corporations that must be audited have to engage SEC-accredited external auditors in the appropriate category.
- Deadlines and exceptions. The circular sets a single filing deadline for companies with a 31 December year end, and late filings are penalized. Companies with a different fiscal year file within 120 calendar days after it ends, and listed and other covered companies follow their own rules. The SEC may also announce extensions, so check each year's circular and notices; dates are tracked in the tax calendar.
- How eFAST treats a filing. Statements filed through eFAST are received automatically and issued a QR code, subject to later review. A report reverted for poor image quality, wrong page orientation, the wrong company profile, the wrong period or submission type, or other errors is treated as not filed. Filings made on a weekend, holiday or work suspension day count as filed on the next working day.
- General Information Sheet. Every corporation files its GIS through eFAST within 30 calendar days of the actual annual stockholders' meeting (the members' meeting for non-stock corporations), and foreign corporations within 30 calendar days of the anniversary of their SEC licence. How to complete it is covered in the GIS guide.
On the BIR side, the income tax page lists CPA-certified financial statements as an attachment to Form 1702 for companies above the threshold. The practical order is: close the books, get the auditor's report, file it with Form 1702 at the BIR, then take the BIR proof of receipt to eFAST. What each step hands to the next is in audited financial statements step by step, and what an AFS means to each agency is in AFS for the BIR and SEC.
One link foreign shareholders often miss: an investor holding an SIRV files an annual report with the Board of Investments that attaches the investee company's audited statements and income tax return as filed with the BIR, plus its GIS. Late company filings can therefore hold up the individual's visa renewal; the visa side is covered in what a Philippine green card means.
Start where you actually are: eight common situations and what to fix first
The main guide walks a new company through a normal year. Real companies rarely start from zero: some have held their tax registration for a month without issuing a single invoice, some have a bookkeeping gap of several months, some sell through online platforms, and some are about to move offices. Find the row that matches you and go to the matching section below. If only one row fits, fix that one first instead of re-running the whole process.
- If you are a newly registered company holding your first Certificate of Registration (COR), take the "after registration" route. Invoice authority, registered books, the notice to issue invoices and the briefing held by your Revenue District Office (RDO) all need to be in place early, and you should expect the RDO to run compliance checks on new registrants after a short interval. See "Keeping your registration current" below.
- If you are still issuing old-style Official Receipts, take the "invoice" route. Invoices have replaced receipts as the primary document; see "What a valid invoice carries" below. Whether you must connect to the e-invoicing system is covered separately in our guide to the e-invoicing rules.
- If you cannot tell whether you count as a micro, small or medium taxpayer, take the "size class" route. The class decides which return you use and which penalty tier applies; see "Four size classes" below.
- If you are unsure whether to file online, at a bank or at the RDO, take the "channels" route. See "E-filing and pay-anywhere" below.
- If you paid a supplier without withholding tax and worry the expense will be disallowed, take the "withholding" route. See "Withholding: when the duty arises" below.
- If your question is where books are kept, for how long, or what happens in an inspection, or if you are closing or moving the company, take the "books" route. See "How long to keep books" below; the full closing process is in our guide to BIR registration and closing.
- If you sell through an online platform or take freelance work under your own name, take the "e-commerce and individuals" route. See our e-commerce tax guide and our guide to opening a Shopee shop; individuals should also read the freelancer registration guide.
- If your books have been neglected for a long time, take the "inventory first" route. First work out whether a filing was rejected, failed in the system, or was simply never made: see the guide to rejected versus failed filings and the guide to late-filing consequences and remedies, then have Yixing's compliance team help scope the catch-up work.
Four size classes: micro, small, medium and large, and what the class changes
The Ease of Paying Taxes Act (EOPT Act, RA 11976) was signed on January 5, 2024 and took effect on January 22, 2024. One of its foundational changes is that taxpayers are sorted by annual gross sales into four classes: micro, small, medium and large. The implementing rules are in RR 8-2024. The class is not just a label. It affects which return you use, which tier of civil penalties applies if you are late, and whether a set of relief measures is open to you. The sales thresholds for each class are set out in RR 8-2024 and the Bureau of Internal Revenue (BIR)'s current announcements; this article does not copy the figures.
How "gross sales" is counted
RR 8-2024 defines the classification base as total sales revenue for the taxable year, net of VAT where VAT applies, without other deductions. It covers business income only, meaning income from trade, business or the practice of a profession. Compensation earned as an employee, passive income under Sections 24, 25, 27 and 28 of the Tax Code, and income excluded under Section 32(B) are not counted. A lot of money moving through the bank account therefore does not automatically mean large gross sales, and the reverse is also true.
How new and existing companies are first placed
- A newly registered business is first classified on the declaration made in its registration forms, then reclassified against the thresholds. The BIR notifies you of your class or reclassification in the manner it prescribes separately.
- Taxpayers registered in 2022 or earlier are classified on their 2022 gross sales.
- Taxpayers registered in 2022 or earlier that never submitted 2022 gross sales, and those registered in 2023 or in 2024 before the rules took effect, start as micro, except VAT-registered taxpayers, who start as small.
In practice, for a company registering today, the gross sales figure you declare on the registration form becomes your starting class. Declare a figure that matches the real business plan; changing it later goes through the BIR's notification process and is not a matter of editing a number.
| Class | Differences confirmed in the official material |
|---|---|
| Micro and small | A simplified two-page income tax return; a lighter tier of civil surcharge for late filing and payment; interest at a reduced rate; compromise penalties cut by half; a lighter fine for failing to file certain information returns; and compromise penalties cut by half for violations of Sections 113, 237 and 238 of the Tax Code (VAT invoicing, registration and invoice issuance). |
| Medium | The relief measures the BIR lists apply to micro and small taxpayers only, so medium taxpayers are subject to the regular penalty tier. |
| Large | Same as medium; in addition, branches register with the Large Taxpayers office where the head office is registered, and withholding tax remittance is a single consolidated return. |
Two cautions. First, you do not choose your class. When sales grow past a threshold the relief measures fall away, so budget for that change in advance. Second, the instructions printed with a return often list penalties separately for "micro and small" and for "medium and large". If you are late, confirm your own class first and then read the matching tier, rather than borrowing another company's experience.
E-filing and pay-anywhere: what goes online and what still needs a window
Since the EOPT Act, two things have changed at the root of filing and payment: filing is electronic by default, and payment can be made at any authorized channel. RR 3-2024 and RR 4-2024 both say that returns are filed through any available electronic platform, and that manual filing is allowed only when the electronic platforms are unavailable. Payment may be made electronically, or manually to an Authorized Agent Bank (AAB) or a Revenue Collection Officer (RCO). The BIR's EOPT flyer adds that you may file and pay with any AAB, at an RDO (through its Revenue Collection Officers) or through an authorized tax software provider.
One detail is easy to miss: AABs and Revenue Collection Officers accept manual payment only after the taxpayer has already filed electronically, unless the BIR issues an advisory allowing manual filing. Walking into a window with a paper return is therefore likely to be a wasted trip. The civil penalty that used to apply for filing at the wrong place is, according to RR 4-2024, no longer imposed.
| Situation | Route | What to keep |
|---|---|---|
| Normal case | File electronically, pay electronically | Both the system confirmation and the payment proof; without one of them you cannot show that both steps were completed |
| You prefer to pay at a bank or window | File electronically first, then pay at an AAB or with a Revenue Collection Officer | The filing confirmation and the payment proof issued by the bank or collecting office |
| Electronic platform is down | Manual filing is allowed | Time of the outage and screenshots, the receiving office's proof of receipt, and the system confirmation later if one is issued |
| You have branches | Quarterly VAT is filed as a single consolidated return; for withholding remittance, non-large taxpayers may file separately for head office and each branch or file one consolidated return | A filing list for each registered location so head office and branch figures do not contradict each other |
| VAT registration cancelled | File the final return and pay within 25 days from the date of cancellation | Proof that the cancellation was accepted |
Keep two concepts apart: filing a return and paying the tax are separate acts, written separately in the law, and missing the due date on either can trigger late consequences. The instructions for the quarterly VAT return (Form 2550Q) also state that as long as VAT registration has not been cancelled, the return is still filed for the quarter even if there was no taxable transaction. Deadlines for users of the electronic filing and payment system (eFPS) are stated in the form instructions as "in accordance with existing applicable revenue issuances", so eFPS users should follow the BIR's current advisories rather than the dates that apply to other users. Which taxpayers must use eFPS and which use eBIRForms is likewise a matter for the BIR's current notices.
Deadlines for each period are collected in the tax calendar guide and are not repeated here, so the two pages cannot drift apart.
Withholding: when the duty arises, and what changed about deductibility
Before the EOPT Act, Section 34(K) of the Tax Code treated "tax was withheld" as a condition for deducting certain expenses, and many companies withheld mainly out of fear that the expense would be disallowed. The EOPT Act repealed that rule, and RR 4-2024 accordingly repeals Section 2.58.5 of the old regulations on additional requirements for the deductibility of certain payments. Read the boundary carefully: the BIR states at the same time that the obligation to withhold tax on the payment and remit it remains. What changed is whether missing withholding automatically costs you the deduction. What did not change is that you must withhold what should be withheld and remit what you withheld.
Failing to withhold or remit carries its own consequences under the withholding provisions. The form instructions state that, in addition to other penalties, willful failure to withhold or remit carries criminal penalties on conviction. For a specific case, consult a practising lawyer; this article is not legal advice.
When the duty to withhold arises
RR 4-2024 redefines the timing: the payor's obligation to deduct and withhold arises when the income becomes payable. Under the amended Section 2.57.4, that means the earlier of two moments: when the payment is accrued or recorded as an expense or asset in the payor's books, or when the seller issues a sales invoice or other adequate document supporting the payable. For whoever keeps the books, withholding is not something to think about "on payment day"; it is something to decide on the day the payable is booked.
| Typical situation | When the withholding duty arises | What to do in the books |
|---|---|---|
| Month-end accrual for services already received, not yet paid | When the accrual is booked | Add a line to the closing checklist: which of this month's new payables fall within withholding |
| Supplier sends an invoice before you have booked it | When the invoice is issued, if that is earlier than booking | Record the date the invoice arrived and decide the period on the earlier moment |
| Purchase of an asset or a prepayment | When it is recorded as an asset | Run the withholding test on asset accounts too, not only expense accounts |
| Actual payment happens later than the moments above | Still the earlier moment | Assign the withholding period by that moment, not by the payment month |
Withholding is reported monthly and quarterly; deadlines are in the tax calendar guide, and the shape of the monthly payroll return, the quarterly expanded return and the annual summary is explained in the guide to tax types and returns.
What the annual information return has to carry
The instructions for the annual withholding return (Form 1604-CF, the version that includes final withholding) list seven alphalists: employees with no previous employer during the year; employees with previous employers; employees terminated before year-end; employees whose compensation is exempt from withholding but subject to income tax; non-rank-and-file employees given fringe benefits; payees subject to final withholding; and minimum wage earners. The deadline printed in that guidance is January 31 of the following year, subject to the BIR's current announcements. The list format is rarely the problem; the lists that nobody maintained during the year are. If joiners, leavers and role changes are not updated in the month they happen, the lists have to be rebuilt from memory at year-end.
What a valid invoice carries, and what a missing field costs you and your customer
The EOPT Act no longer requires an Official Receipt; the invoice is the primary evidence of a sale of goods or services. RR 7-2024 says receipts, collection receipts and payment receipts may still be issued as supplementary documents showing that payment was made, but they are not invoices. RR 3-2024 also replaces the old terms "gross selling price" and "gross receipts" with "gross sales" and moves sales of services to the accrual basis, so one invoice now has to do three jobs: invoicing, recognising the sale, and supporting the buyer's input tax.
The transition period is over
- Unused old receipts could still be used up as supplementary documents, but only with "THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX" stamped on the face.
- The rules once allowed a taxpayer to strike through "Official Receipt" and stamp "Invoice" on unused stock until December 31, 2024. Any receipt issued after that date, stamped or not, is a supplementary document and cannot support an input tax claim.
- Cash registers, POS machines and e-invoicing software had until June 30, 2024 to be reconfigured. After that date, issuing an "Official Receipt" for a sale is not accepted as evidence of the sale and is treated as failing to issue an invoice, which is penalised.
A company that still issues receipts therefore does not have an "old format" problem; it may be treated as not having invoiced at all.
What a valid invoice carries
Section 6 of RR 7-2024 lists the elements of an invoice in general, and Section 3 adds requirements for VAT-registered persons. Together they give this checklist for the books:
- Seller details: the seller's name as shown on its BIR Certificate of Registration (optionally with its DTI business name or SEC trade name); a statement that the seller is VAT or non-VAT registered, followed by its TIN and branch code; and the registered business address. "Business style" is no longer mandatory information on an invoice.
- Document identity: the word "Invoice" printed or included (Sales Invoice, Cash Invoice, Service Invoice and similar); a prominent serial number; and the date of the transaction.
- Buyer details: space for the buyer's registered name, address and TIN. Direct business-to-consumer sales to end users do not require the buyer's details. For sales to a VAT-registered buyer above the prescribed threshold, the buyer's name, address and TIN must be shown; the threshold is in the rules and the BIR's current announcements.
- Transaction content: quantity, unit cost, description of goods or nature of the service; a total that includes VAT where VAT applies; and the VAT amount as a separate item.
- Special sales: "VAT-Exempt Sale" for exempt sales and "Zero-Rated Sale" for zero-rated sales; a breakdown where one invoice mixes taxable, exempt and zero-rated sales; and the word "EXEMPT" on the face of a non-VAT invoice where neither VAT nor percentage tax applies.
- Special customers: when dealing with senior citizens, persons with disability, national athletes and coaches, solo parents, or Medal of Valor awardees and their qualified dependents, the invoice needs space for the ID number, the discount breakdown and a signature. For online or mobile-app purchases by senior citizens and persons with disability, a physical signature is not required.
- Printing and system information: manual invoices show the authority to print or Outbound Correspondence Number and date issued; loose-leaf invoices show the BIR permit number and series range; invoices from cash registers or POS machines show the machine identification number and final permit to use number; and a reprint from a system must be prominently marked "REPRINT".
Tickets such as transport, event, parking or raffle tickets can serve as both invoice and proof of payment if the word "Invoice" is printed on them and they carry all the required information. Otherwise they are only supplementary documents and a separate invoice must be issued.
Who is hurt by a missing field
| What is wrong with the invoice | Consequence for the issuer | Effect on the buyer's input tax |
|---|---|---|
| A VAT invoice lacks required information | The issuer is liable for non-compliance | Input VAT is still creditable unless the missing item is the amount of sales, the VAT amount, the registered names and TINs of both parties as on their certificates of registration, the description of goods or nature of services, or the date of the transaction |
| A non-VAT-registered person issues a "VAT invoice" (showing a VAT label or a VAT TIN) | Liable for VAT, with no input tax credit, plus a surcharge, on top of any percentage tax | If the invoice shows the seller's VAT registration statement and TIN as the rules require, the buyer can still recognise the input tax |
| A VAT-registered seller invoices an exempt sale without "VAT-Exempt Sale" or a breakdown | Treated as liable for VAT as if the exemption did not apply | The rules do not spell out the buyer's position on this point; follow the BIR's current guidance for the specific case |
| A delivery receipt, order slip or collection receipt is used as the evidence | Not treated as an invoice | Supplementary documents are not valid for input tax, which is why they must carry "THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX" on their face |
As a buyer, check three things on the day an invoice arrives: whether the name and TIN match your own registration, whether VAT is shown separately, and whether the date and description are complete. An input claim with the wrong name is hard to rescue afterwards. To check whether a supplier is genuinely registered, see the supplier due diligence guide. Who has to connect to the e-invoicing system is covered separately in the e-invoicing guide.
How long to keep books, in what form, and what an inspection looks like
Most people know only that books must be kept "for a long time". Section 4 of RR 7-2024, which implements Section 235 of the Tax Code, is quite specific. What follows tracks its wording.
How long and in what form
Books of accounts, including subsidiary books, and other accounting records must be preserved by the taxpayer for 5 years, counted from the day following the deadline for filing the return, or from the date of filing if the return was filed late, for the taxable year in which the last entry was made. The "last entry" is the transaction entered or posted last when the books were closed. "Other accounting records" include the corresponding invoices, receipts, vouchers and returns, and the other source documents supporting the entries.
| Type of books | Form of preservation |
|---|---|
| Manual books of accounts and other accounting records | Hard copies |
| Manual bound loose-leaf books and other accounting records | Hard copies |
| Computerized books of accounts and other accounting records | Electronic copies |
The period is 5 years for all three; only the form differs. Five years is a floor, not a ceiling: if you have a pending protest or a claim for tax credit or refund and the books are material to the case, you must keep them until the case is finally resolved, even beyond 5 years. The independent CPA who audited and certified your financial statements also has to keep electronic copies of the audited statements and the audit working papers for 5 years, counted from the due date of the annual income tax return or the actual filing date, whichever is later. If older material tells you a different period, follow RR 7-2024 and the BIR's current announcements.
What happens in an inspection
- Condition: books, registers, records and vouchers must be kept intact, unaltered and unmutilated, at the place of business, and produced immediately when an internal revenue officer demands them.
- Place: the examination takes place at the taxpayer's office or place of business, or at a BIR office.
- Frequency: for income tax purposes, examination and inspection is made only once in a taxable year, with five exceptions: fraud, irregularity or mistakes as determined by the Commissioner; a taxpayer's request for reinvestigation; verification of compliance with withholding tax rules; verification of capital gains tax liabilities; and a separate examination under the Commissioner's power under Section 5(B) of the Tax Code to obtain information from other persons.
- Purposes: examination may also serve an audit, an exchange-of-information request from a foreign tax authority, and other uses within the Commissioner's power to obtain information.
- Tax-exempt organizations and incentive grantees: their books can also be examined to check compliance with the conditions of the exemption or incentive.
When a business stops or dissolves
A corporation, partnership or person that retires from business must, within 10 days from the date of retirement or within such period as the Commissioner allows in special cases, submit its books of accounts, subsidiary books and other accounting records to the Commissioner or a deputy for examination, after which they are returned. Corporations and partnerships contemplating dissolution must notify the Commissioner and may not be dissolved until cleared of any tax liability. The closing process is covered in the guide to BIR registration and closing.
In practice this section affects three everyday actions: which boxes you cannot throw away when you move offices; which originals and electronic backups you must take back when you change bookkeeper, see the guide on doing it yourself and changing agents mid-way; and how to respond, in order, when an audit notice arrives, see the BIR audit guide. For how to register the books themselves and how to choose between manual, loose-leaf and computerized, see the books of accounts guide.
Keeping your registration current: posting the certificate, online display, moving, closing, and checks on new companies
Registration does not end when you receive the COR. A set of upkeep duties follows, mostly in Section 5 of RR 7-2024, which implements Section 236 of the Tax Code. The table below organises them by topic.
| Topic | Rule | Where people slip |
|---|---|---|
| When business is treated as started | From the first sale, or when 30 calendar days have passed from the issuance of the mayor's permit, professional tax receipt, DTI business name certificate or SEC certificate, whichever comes first. Failing to register with the BIR within that period is a violation. | Watching only the SEC date and forgetting that the local permit also starts the clock |
| Posting the certificate | The COR (or electronic COR) must be posted at the place of business and at each branch, clearly visible. | Forgetting to post it again at a new branch or after a move |
| Online display | Businesses operating through a website, social media or other digital means must display an electronic copy of the COR conspicuously on the site, seller page or app. E-marketplace operators also require sellers to submit the COR (BIR Form 2303) as one of their minimum accreditation requirements. | Uploading it in the back office where buyers cannot see it |
| Business names, including online store names | Each business name used, including an online "store name", must be registered with the BIR and reflected on the COR, and must be backed by an SEC or DTI registration. | Changing the store name without updating the registration |
| Each type of tax | Register each type of internal revenue tax you are liable for, file and pay, and update the registration when things change. | Filing on the old tax mix after a change; updates use Form 1905 |
| Annual registration fee | Repealed effective January 22, 2024. A COR that still shows the fee remains valid, and needs updating only when registration information changes. | Paying it every January out of habit |
| Cancelling registration | Cancelled upon the mere filing of an application for registration information update with the RDO where you are registered; the BIR may still audit to determine any tax liability. | Assuming cancellation wipes the slate clean |
| Moving or transferring registration | File the application at the current RDO and obtain a new COR from the new RDO. Open cases and stop-filer cases are settled at the new RDO, except where an audit investigation has started, in which case the RDO that started it continues. | Assuming that moving leaves old problems behind |
One more thing happens on the RDO's side. Newly registered businesses are included in the RDO's monthly Tax Compliance Verification Drive (TCVD) after 30 calendar days from registration, to validate the declarations in their applications and verify that the business exists; a business that transfers registration is likewise included by the new RDO 30 calendar days after the new COR is issued. A company that has only just opened and has little revenue should therefore keep the address, business scope and contact details on its registration accurate and reachable. Carrying on business without registration is punishable under Section 258 of the Tax Code.
Which window handles SEC, BIR and the city hall, and how the location is decided, is covered in the guide to where to file a company registration. For a company being set up from scratch, see Yixing's company setup service.
Common blockers: why filings get rejected, corrected, or noticed by the BIR
This section lists no "things to note"; it explains why things stall. The first four are "done but does not count"; the last four are "not done, but you thought it was".
- Filed but not paid, or paid but not filed. The law treats filing and payment as separate acts, and banks and collecting officers accept manual payment only after electronic filing. If either the system confirmation or the payment proof is missing, it is hard to prove later that you completed the other half.
- The return does not match the tax types on the COR. The tax types listed on your COR decide which returns you file. If the tax mix changed and no update was made, filings continue on the old mix.
- The name, TIN or branch code on an invoice differs from the registration. For the issuer this is non-compliance; for the buyer it can mean a lost input tax claim. The items whose absence defeats an input tax claim under RR 7-2024 include the registered names and TINs of both parties.
- The type of books does not match how they are used. Manual, loose-leaf and computerized systems each have their own registration and permit requirements, and using first and registering later is the most common mistake. How to choose is in the books of accounts guide.
- The RDO was never updated after a move. Open cases and stop-filer cases travel with the registration to the new RDO; problems at the old RDO do not disappear because you moved.
- Using old deadlines and form versions. The instructions for the same return can describe certain deadlines differently across versions, which shows that deadlines and forms are adjusted. Follow the BIR's current announcements, not old articles or old templates.
- Assuming micro and small relief applies automatically. Class follows the registration declaration and the BIR's notices; it changes as sales cross thresholds and is not established by the company simply stating it.
- Looking for the books only after an audit arrives. Books must be kept at the place of business and produced immediately on demand. Not having the books at hand, or having the originals sit with an outside agent, is the weakest position in an audit. The boundary of outsourcing is in the guide to tax agents and outsourced bookkeeping, and checks before choosing an agent are in the guide to choosing a bookkeeping and tax agent.
The downside: what is slower, costlier, or likely to waste a trip
Listing the benefits is not enough. These are the unfavourable points we found while reading the official documents, stated up front.
- Going to a window with paper forms may waste a trip. Filing is electronic by default, manual filing is allowed only when platforms are unavailable, and banks and collecting officers accept manual payment on the condition that the return was filed electronically.
- Relief measures are not for everyone. The relief measures the BIR lists apply to micro and small taxpayers only. Once sales cross a threshold the measures fall away, so budget for that change in advance.
- Five years is not "throw it away when it expires". While a protest or refund claim is pending you must keep the records until the case ends, and in an audit the burden of showing incomplete or missing originals falls on the company.
- Moving, renaming and changing tax types are registration changes. Saying "we moved" does not complete anything, and open cases follow the registration to the new RDO.
- The longer books are neglected, the harder they are to fix. Take inventory first, then catch up the books, then catch up the filings; the wrong order means rework, and catch-up work gets costlier the longer it waits.
- Outsourcing does not transfer responsibility. The filing entity is always the company, and signatures and legal consequences rest with the company; the agent is only the executor.
- Rules and form versions change quickly. Parts of the BIR website load dynamically, so the guidance you see can differ from one day to another. This article checks key points against the regulations and form instructions, but deadlines remain subject to the BIR's current announcements.
- Not suitable for reading alone. If you have received an audit notice, dispute an assessment, or face criminal exposure, consult a practising lawyer or a certified public accountant; this article is not legal advice.
Yixing is a private consulting company; it is not the BIR and does not represent any government agency. Determinations and approvals rest with the competent authority, and we help with compliant documents and follow-through. If you want someone to check your company's position against the current requirements, contact Yixing's compliance service.
Official sources and last check
The content of this section was checked against the official pages and documents below; deadlines and form versions are subject to the BIR's current announcements.
- Bureau of Internal Revenue website: announcements, forms and the entry point to electronic services.
- BIR Ease of Paying Taxes page: the entry point for the EOPT Act (RA 11976).
- BIR EOPT Act flyer: signing and effective dates, file and pay anywhere, repeal of the registration fee, relief measures.
- RR 7-2024 (published in the Official Gazette): registration, invoicing and preservation of books.
- RR 8-2024 digest: classification of taxpayers.
- RR 3-2024 digest and RR 4-2024 digest: VAT and percentage tax, filing and payment methods, timing of withholding.
- BIR Form 2550Q guidelines (April 2024 version): who files, when, and penalties by class.
- BIR forms page: the official download entry for returns and instructions.
Note: the BIR website's EOPT page and some other sections load dynamically. Where the page text could not be read in full, this article does not rely on it and instead follows the regulations and form instructions. Form instructions carry different version years, so deadlines and penalties are subject to the BIR's current announcements.
Last checked: September 2026.
Do it yourself, hire a bookkeeper or outsource, and how to catch up on missed filings
Any of the three approaches can work, but the filing obligation always stays with the company. The choice turns on transaction volume, whether you have employees, whether you are VAT-registered, and whether anyone inside the company can own the deadlines.
| Approach | Suits | Main risks |
|---|---|---|
| Owner or staff do it | New, low-volume companies with no employees and no VAT registration | Unfamiliar forms and dates; filings slip when things get busy; books registration and document control get neglected |
| Part-time bookkeeper | Mid-volume companies that need someone to reconcile every month | Dependence on one person and gaps when they leave; audit and SEC filings may fall outside their scope |
| Outsourced bookkeeping or tax agent | Companies with employees, VAT registration or high volume, or managers new to local rules | Working papers kept only by the provider; unclear handover of authorizations and online accounts; filings pushed to the last day |
Whichever you choose, the company should hold three things itself: its BIR registration documents and registered books, every filed return with proof of payment, and its BIR and SEC online accounts. What is really being outsourced, and how to switch providers without a gap, is covered in tax agent and bookkeeping services.
Consequences of missed filings, by type only. The BIR penalties page lists a surcharge (Section 248 of the National Internal Revenue Code), interest (Section 249), and compromise penalties under the schedule annexed to Revenue Memorandum Order No. 7-2015. Section 255 adds criminal liability for willful failure to file, pay, keep records, or withhold and remit, and Section 250 penalizes failure to file information returns or keep required records. On the SEC side, late financial statements are also penalized. Amounts follow the BIR's and SEC's current rules. Individual cases belong with a licensed accountant or lawyer; this guide is not legal or tax advice.
A practical catch-up order
- Take stock: confirm with the company's RDO which periods and tax types are unfiled, and gather bank statements, invoice copies and purchase documents.
- Rebuild the books: post the missing periods into the registered books. Without them, late returns have nothing to rest on.
- File the late returns period by period, settling surcharge and interest where tax is due. Where statements still need an audit, follow the BIR-then-SEC order.
- Fix the process: write down deadlines, owners and document handovers so the same gap does not open again.
If the BIR has already issued an audit notice, the order changes; see BIR tax audits and the Letter of Authority. The knock-on effects of late or missing audited statements are covered in late audited financial statements.
Books already months behind and unsure where to start? Let Yixing map the unfiled periods and set the catch-up order → · Yixing compliance management
Frequently Asked Questions
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