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Clarifications on the Filing of Monthly Documentary Stamp Tax Declaration by Electronic Documentary Stamp Tax (eDST) Taxpayers using BIR Form No. 2000 v 2018
03 Oct 2024
(Revenue Memorandum Circular No. 95-2024, August 29, 2024)
This Tax Alert is issued to inform all the concerned of the clarifications on the issues and concerns raised by the taxpayers who are using the eDST System and who are filing the BIR Form No. 2000 v2018 thru the electronic Filing and Payment System (eFPS) pursuant to Revenue Memorandum Circular (RMC) No. 48-2024.
The BIR clarified that the filing of BIR Form No. 2000, when used as declaration for taxable transactions in computing total DST due, is a compliance requirement as a tax return and it is not being used in paying total DST due. Hence, penalties on late payment of DST should not apply as the DST was already paid in advance in the form of deposit.
Below are the specific issues and clarifications provided by the BIR on the filing of Documentary Stamp Tax Declaration by eDST Taxpayers using BIR Form No. 2000 v2018:
| Issue | Clarification | |
| 1 | Additional requirement of filing BIR Form No. 2000 for declaring the total DST due for the month considering that these taxable transactions are already encoded in the taxpayer’s ledger of the eDST System as utilizations from their advance deposits | The filing of BIR Form 2000 for remittance of advance deposits by taxpayers-users of eDST system, is not yet a return, but as a payment form. Due to certain limitations of the current format of BIR Form No. 2000 v2018, the same form shall still be used separately in declaring the taxable transactions in the computation of the total DST due of these taxpayers-users, pending the revision of the said form. |
| 2 | Sudden suspension of encoding the transactions in Schedule 1 (Summary of Computation of Taxes Due for the Month) of the said form due to voluminous transactions. Thus, the taxpayers/users are compelled to terminate the encoding process and the previously encoded transactions are lost. | For purposes of addressing the technical limitations of the eFPS in accomplishing Schedule 1 of the form involving voluminous transactions, the encoding of Alphanumeric Tax Code (ATC) No. 010 and the amount under the “Tax Due” column equivalent to the total tax due for the month reflected in the taxpayer’s ledger of said system shall be sufficient. |
| 3 | Inability to generate the form or delay in filing the declaration within the prescribed deadline (five (5) days after the close of taxable month) by reason of several attempts to accomplish Schedule 1 and generate the form. Consequently, penalties are automatically computed due to late filing of the form. | The taxpayer-user cannot be held liable for penalties computed by the eFPS because the DST dues were already paid in advance in the form of deposit and the utilizations thereof can be validated from the eDST system. Considering that the current eFPS cannot distinguish whether the said form is being filed as a tax return or as a declaration, the corresponding amount for compromise penalty for late filing of the said form as a declaration shall be the only penalty of the eDST user. |
| 4 | The total penalty computed by eFPS is based on the total tax due which is a very significant amount on the part of the taxpayers as it is not proportion of filing of a simple declaration within the prescribed deadline. | The compromise penalties resulting from non-filing or late filing by eDST taxpayers-users of the said form as declaration covering previous taxable months from the date of issuance of RMC No. 48-2024 shall no longer be assessed and collected. |
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