Fresh guidelines on filing of BIR Forms

Happy New Year! Is it too late to greet everyone a happy and healthy new year? Well, Chinese New Year is just around the corner, so please accept this greeting from me to you.

With all our new year wishes also comes every taxpayer’s burden—annual tax deadlines that coincide with the monthly deadlines of the new year. These can become a confusing, obscure haze of deadlines, filing, and more deadlines. One thing that taxpayers may have missed out is the newly issued BIR Revenue Memorandum Circular (RMC) No. 04-2021, dated and issued last January 8, 2021.

The RMC includes guidance for manual filers to file their taxes through the eBIRForms facility. Payment of taxes may be done through either the (1) Authorized Agent Banks (AABs) of their respective Revenue District Offices (RDOs), (2) through Revenue Collection Offices of the RDO (in the case where there are no AABs), or (3) through the online payment options such as DBP Pay Tax Online, LandBank Link.Biz Portal, Unionbank Online Web and Mobile Payment facility, or through e-wallets Gcash or PayMaya. Simple; no need to go out of the house or office in filing and paying taxes.

However, Electronic Filing and Payment System (EFPS)-registered taxpayers may have missed out an itsy-bitsy, teeny-weeny detail in the RMC.

Under Section I (B) of the RMC, in the case where the tax return in the EFPS account has not been updated to the latest version, the BIR has mandated EFPS taxpayers to file tax returns using the eBIRForms facility and pay through the channels stated above, making the EFPS taxpayer as a hybrid between manual and EFPS filer.

Every year, the BIR releases issuances announcing the availability of new BIR Form versions. Reasonably enough, updated BIR Forms help us cope with the changing times and laws of our country. With the introduction of the TRAIN Law in 2018, and the looming enactment of the CREATE Bill, we can expect to see even more issuances on the availability of new BIR Forms.

Notably, most—if not all— related issuances from the BIR are directed specifically only to the available forms in the eBIRForms facility, while EFPS taxpayers are advised to use the old versions found in their EFPS accounts. However, this year the BIR put a stop to that old practice by mandating the EFPS taxpayers to file and pay the new versions of the tax returns through the eBIRForms facility.

What should EFPS taxpayers do to adjust to this new circular?

First, it is advisable to follow the wording of the issuance—that is, to file for the updated tax returns using the eBIRForms facility and pay through the channels stated above. Note that an EFPS filer cannot file through the EFPS and pay through AABs, RCOs or online payment channels, or the other way around; this would be construed as wrong venue of the payment subject to penalties under the Tax Code. For those updated tax returns, the EFPS filer may continue to file and pay through the EFPS, while updated tax returns not yet reflected in the EFPS account must be filed through the eBIRForms facility and paid through AABs, RCOs or online payment channels.

Second, keep a copy of all the files received during filing and paying the tax return through eBIRForms facility. To summarize the procedures, once the tax return has been submitted as final in the eBIRForms facility, an acknowledgement email will be sent by the BIR to the eBIRForms registered email. This will serve as an acknowledgement of the tax return. The payment form or acknowledgement receipt for payment will vary depending on the mode of payment used by the taxpayer. Safekeep all these records as one would in using the EFPS and create unique identifiers that these tax returns have been filed by virtue of RMC No. 4-2021.

Third, always update the eBIRForms facility on your computer. As of writing, the updated eBIRForms is version 7.7. Always remember that the BIR issues most new and updated versions of tax returns per version release of the eBIRForms.

Lastly, always stay updated on the latest BIR updates. Besides monitoring the official BIR website, where all tax return versions are updated, one could also subscribe to fora, webinars, and publications, including P&A Grant Thornton’s Tax Notes, a weekly publication of the latest tax trends. A simple timeline will also be helpful in identifying which BIR Forms have been updated.

One may say that this is being done by the BIR as a means of uniformity among manual and EFPS taxpayers. In this manner, the BIR can track, monitor, and audit tax returns in a uniformed fashion, eliminating the focus from the version of the BIR Form to the actual contents of the BIR Form—the taxes with which our country’s lifeblood relies on.

Others may also say that this is an additional burden to the taxpayers, but who’s to say that the administrative feasibility promised to us by the Tax Code has no cost? It does. These are the minute costs that we must spend in order to maintain a better taxation system among government and taxpayers. While we focus on our own tax concerns, we also need to look at the bigger picture and hope that someday, these itsy-bitsy, teeny-weeny, details would pave the way for a better country ahead.

Joen Ramas is an Associate of the Tax Advisory and Compliance Division of the Cebu branch of P&A Grant Thornton. P&A Grant Thornton is one of the leading audit, tax, advisory, and outsourcing firms in the Philippines with 22 Partners and more than 900 staff members. We’d like to hear from you! Tweet us: @GrantThorntonPH, like us on Facebook: P&A Grant Thornton, and email your comments to joen.ramas@ph.gt.com or pagrantthornton@ph.gt.com. For more information, visit our website: www.grantthornton.com.ph

As published in Mindanao Times, dated 08 February 2021