Through Revenue Memorandum Circular (RMC) No. 55-2026, the Bureau of Internal Revenue (BIR) reminded businesses that proper documentation and submission of attachments are an integral part of withholding taxes. 

Under RMC No. 55-2026, the BIR reiterated the obligation of electronic marketplace (e-marketplace) operators and digital financial services providers (DFPs) as withholding agents to attach the alphalist when they file their withholding tax returns. 

For some businesses, this circular may sound technical. Here are some of their questions: 

What is a withholding agent, and what do they do? 

Under previously issued Revenue Regulation (RR) No. 16-2023, as amended by RR No. 5-2025, e-marketplace operators and DFPs are identified as withholding agents. 

Withholding agents are required to withhold 0.5% tax on gross remittances made to sellers of goods and services and remit these taxes to the government.

In simple terms, they act as collectors on behalf of the BIR. Before making payments to suppliers, employees, and service providers, they are responsible for deducting taxes and remitting them directly to the government, rather than waiting for them to pay taxes later. 

Why is the alphalist important for withholding agents? 

An alphalist is a detailed report containing the names of employees, sellers, suppliers, or payees subjected to withholding tax, the amount paid, and taxes withheld. 

The BIR uses this report to verify whether the taxes that are withheld and remitted by the business match. 

That is why, under RMC No. 55-2026, the BIR emphasized that withholding agents must submit alphalists as an attachment to their tax returns. 

According to the BIR, since alphalist forms are part of the withholding tax return, submitting them is likewise part of the withholding agent’s obligation.

What happens if a business fails to submit the alphalist? 

Under RMC No. 55-2026, the BIR outlined that the submission of the alphalist depends on the specific withholding tax return and its corresponding deadline, as follows: 

If a withholding agent fails to submit the alphalist, it will be deemed as a violation of BIR regulations, and may result in corresponding penalties such as compromise penalties, surcharge, and interest, or may trigger a BIR audit and investigations. 

The reminder of the BIR is pretty simple —  for businesses acting as withholding agents, withholding and remitting payments are not the only priorities. Ensuring alphalists, other required attachments, and timely filing are also essential rules to obey in order to ensure compliance and avoid penalties. – Rappler.com

Mon Abrea is a Global Tax Policy Expert and Chief Tax Advisor of the Asian Consulting Group (ACG), the Philippines’ premier tax advisory and investment consulting firm—providing tax strategy, compliance, and policy advisory services to multinational corporations, foreign investors, and government institutions. For strategic tax advisory, CONSULT ACG, or you may also send an email to consult@acg.ph to host investment and tax briefing in key cities across Asia, Middle East, Oceania, Europe and North America.