Yes, filing of withholding tax returns had become quarterly but wait, amount withheld still needs to be remitted monthly using the BIR Monthly Remittance Forms, BIR Form Nos. 0619E and/or 0619F.
“…taxes withheld by the withholding agents are held in trust for the government and its availability is an imperious necessity to ensure sufficient cash inflow to the National Treasury”
Revenue Regulations 11-2018
Per Revenue Regulations No. 11-2018, withholding agents shall file BIR Monthly Remittance Form (BIR Form Nos. 0619E and/or 0619F) every 10th day of the following month when the withholding is made, regardless of the amount withheld.
For withholding agents using the eFiling and Payment System (eFPS) facility, the due date is on the 15th day of the following month. Withholding agents with zero remittance are still required to use and file the same form.
Just a gentle reminder that these forms are to be used in remitting every first and second months of the quarter only. The quarterly withholding tax returns (BIR Form Nos. 1601EQ and/or 1601FQ) are to be used in remitting the amount withheld for the third month. These will be accompanied by the Quarterly Alphabetical List of Payees (QAP). That’s right, no more monthly alphalist.
Release of the new forms
On the very late afternoon of May 10, 2018, the very first deadline of monthly remittance after RR 11-2018 was issued, BIR released the enhanced eBIRForms version 7.1 (v7.1) which contains the BIR Form Nos. 0619E and 0619F.
However, the forms were not yet available for eFPS filers as of the first deadline which was May 15, 2018. This was pretty predictable to happen for many reasons that were too obvious to mention if you work that much with BIR matters, so I already went to BIR ahead of the deadline to inquire about options for eFPS filers.
The thing with eFPS filers is that they could be considered filing in the wrong venue if they don’t file through eFPS, unless a separate issuance was released to do otherwise, just in the filing of BIR Form No. 1701Q.
In my conversation with BIR personnel few days before the deadline, they suggested to wait for the BIR Form Nos. 0619E and 0619F in eFPS until the deadline which was May 15. And if they do not become available by then, eFPS filers should follow the transitory procedure as released in their Tax Advisories before, that is to use BIR Form No. 0605 for remittance.
Can we hold BIR to their word? Not really. If it’s not on a BIR issuance, it’s not BIR’s word. Though the February 6, 2018 Tax Advisory includes a statement that the use of BIR Form No. 0605 is “a transitory procedure pending the issuance of the enhanced withholding tax remittance forms.” [Emphasis added.] That could be a good justification.
Can we take their word for it? Sort of. I don’t always get the perfect answers from BIR officers-of-the-day or other BIR personnel at RDO, but they sure do make sense most of the time. They already get the hang of how their National Office works.
Do eFPS filers have better options aside from above? Not much.
So it’s up to eFPS filers now. The principle behind BIR Form Nos. 0619E and 0619F is to make the funds available to the National Treasury anyway, so I personally think using the BIR Form No. 0605 would do good.
…the forms. We’re talking about the forms. 😉
Update (06/04/2018): Per Revenue Memorandum Circular No 27-2018, in case of system down or the returns are not available in the eFPS filers account, eFPS filers shall still use BIR Form No. 0605 or the new remittance form under BIR Form No. 0619E/0619F once available, in filing and remitting the creditable taxes withheld (expanded)/final income taxes withheld for the month. This makes our workaround above official. 🙂 BIR Form Nos. 0619E and 0619F are not yet available on eFPS though.
Update (06/13/2018): Per Revenue Memorandum Circular No. 50-2018, eFPS taxpayers shall follow the staggered filing due dates based on industry grouping. You may note that the deadline provided under RMC No. 50-2018 in the case of eFPS filers may be earlier, depending on grouping, than the deadline provided under RR No. 11-2018 which is every 15th. For example, Group E eFPS filers are required to file BIR Form No. 0619E/F on the 11th under RMC No. 50-2018 but the same is still due on the 15th following the deadline prescribed by RR No. 11-2018. Of course, it is wiser to file at the earliest time possible to avoid potential penalties for late filing.
Update (08/10/2018): Per BIR Tax Advisory, eFPS filers do not need to file BIR Form No. 0605 if there is no remittance made. No penalties shall be imposed for this. Once BIR Form Nos. 0619E and 0619F are already available in the eFPS, then eFPS filers are required to file the applicable form with or without remittance to be made.
Update (09/04/2018): BIR Form Nos. 0619E and 0619F are already available in eFPS. eFPS filers may check their accounts and start remitting withholding taxes using these forms.