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Let's Talk Tax

Wish list for reforms on tax filing, payment and administrative compliance

It’s been more than a year since the onset of the COVID-19 pandemic. This global health crisis, which has claimed millions of lives and continues to change the ways businesses operate, has spanned two tax seasons in the Philippines.

In 2020, when the pandemic was declared and lockdowns were imposed, the April 15 deadline for filing and payment of annual income tax returns (AITR) was extended for two months. This year, the government did not heed the taxpayers’ call for an extension in filing and payment of annual income tax for tax year 2020. Instead, the following measures were implemented to alleviate hardship in meeting the deadline during these challenging times:

• Amendments to the 2020 annual income tax return have been allowed without penalty until May 15, 2021;

• Out-of-district filing and payment of tax returns falling due on March 22, 2021 to April 30, 2021 has been allowed;

• Use of electronic signatures on 2020 annual ITRs, attachments, and documents has been allowed; and

• Taxpayers may opt to submit copies of electronically-filed AITRs and attachments via the eAFS Facility of the Bureau of Internal Revenue (BIR). Attachments to electronically filed AITRs are due on April 30, 2021 or 15 days from electronic filing, whichever comes later.

Indeed, the above measures have eased the burden of filing and paying taxes under stricter quarantine guidelines implemented by the government. However, the measures were announced by the government less than three weeks from the filing deadline. Hence, the following reforms on tax filing and payment in line with the aforementioned circumstances and other administrative tax compliance requirements, some of which are also embodied under the proposed House Bill No. 8942 or the “Ease of Paying Taxes Act,” may be considered by the government:


Under the Tax Code, except in cases which the Commissioner otherwise permits, tax returns are required to be filed with an authorized agent bank, Revenue District Officer, or Collection Agent in the Revenue District Office (RDO) where the taxpayer is registered.

To address the influx of taxpayers filing and paying their annual income tax returns close to the April 15 deadline, the BIR normally issues memorandum circulars allowing out-of-district filing and payment for tax returns due during the tax season. Unless the BIR issues a circular which normally covers only specific tax returns, taxpayers are obligated to file and pay their taxes in the RDO where they are registered, regardless of where they are during the time of filing. Failure to file and pay at the correct venue is subject to penalty. This creates an additional burden and inconvenience to taxpayers due to safety and travel restrictions during the pandemic.

In this regard, the file-and-pay-anywhere system must be institutionalized to relieve taxpayers of the extra burden of awaiting for a memorandum circular allowing them to file and pay out of district. Since this will be more convenient for taxpayers, this measure could result in higher tax collections.

Penalties for filing and paying in the wrong venue should accordingly be abolished, too.


Currently, except for certificates of withholding taxes (BIR Form 2304, 2306, 2307 and 2316) and the 2020 AITR and attachments, the BIR still requires wet signatures in tax returns, forms, and documents due to be submitted to the BIR. Also, a number of tax returns and submissions relating to tax assessments still require manual submission. 

With the ongoing pandemic and initiatives to comply with the Ease of Doing Business and Efficient Government Service Delivery Act of 2018, the BIR should allow the use of electronic signatures and electronic submission of documents/letters to the BIR. This will not just be more convenient for taxpayers, but it will also save the BIR storage costs and time spent looking for lost dockets.


For the sale of goods or property, sellers are required to declare and remit VAT based on gross sales during the period. On the other hand, for sales of services or lease of goods or property, sellers are required to declare and remit based on gross receipts during the period. A VAT sales invoice must be issued for the sale of goods or property. A VAT official receipt must be issued for the sale of services or lease of goods or property.

This distinction often causes confusion among taxpayers, especially businessmen who are not tax practitioners and foreign investors who are not savvy about our tax intricacies. This distinction also raises issues regarding differences in timing of reporting and claiming of input VAT by sellers and purchasers, resulting in significant discrepancies in case of third-party matching of information by the BIR.

All things considered, legislators should indeed look at removing the distinction between sale of goods and services for VAT purposes. For easy monitoring and compliance, VAT should be based on gross sales/selling price, regardless of whether it is a sale of goods or services. In both instances, a VAT sales invoice should be issued upon sale and a non-VAT official receipt must be issued upon collection.


Taxpayers should be allowed to pay taxes without unnecessary documentary requirements. The act of paying taxes should be the easiest part of tax compliance. While in other stages of tax compliance, proof that the representative is authorized by the taxpayer may be needed, there should be no further proof required for payment of taxes. Paying taxes on behalf of another taxpayer will not in any way disadvantage the government. Hence, unauthorized payment of taxes should not be an issue for the tax bureau.

The above suggestions are just some of the reforms which our legislators and the BIR may consider. As these measures will indeed help ease tax compliance, and accordingly, improve compliance levels of businesses in the Philippines, I do hope that these reforms could materialize soon as they can help raise taxes that would add to the government’s capacity to mitigate the effects of the pandemic.

Let’s Talk Tax is a weekly newspaper column of P&A Grant Thornton that aims to keep the public informed of various developments in taxation. This article is not intended to be a substitute for competent professional advice.


Ma. Lourdes Politado-Aclan is a director from the Tax Advisory & Compliance division of P&A Grant Thornton, the Philippine member firm of Grant Thornton International Ltd.


As published in BusinessWorld, dated 27 April 2021