Title
Amendment on withholding tax for top taxpayers
Law
Bir Revenue Regulations No. 6 - 2009
Decision Date
Jun 3, 2009
BIR Revenue Regulations No. 6-2009 establishes additional criteria for identifying the Top 20,000 private corporations and the Top 5,000 individual taxpayers, imposing creditable withholding tax on income payments related to agricultural products exceeding P300,000 within a taxable year.
A

Creditable Withholding Tax on Income Payments by Top 20,000 Private Corporations

  • Applies to income payments by Top 20,000 private corporations to local/resident suppliers of goods and services.
  • Includes non-resident aliens engaged in trade or business in the Philippines.
  • For agricultural products in their original state, withholding tax applies only when purchases exceed P300,000 per taxable year.
  • Agricultural products covered include corn, coconut, copra, palay, rice, cassava, sugar cane, coffee, fruits, vegetables, marine food products, poultry, and livestock.
  • Withholding tax rates:
    • Supplier of goods: 1%
    • Supplier of services: 2%
  • Criteria to be included in Top 20,000 Private Corporations:
    • Large taxpayer classification or inclusion in previous top taxpayer lists.
    • VAT payment or payable of at least P100,000.
    • Annual income tax due of at least P200,000.
    • Percentage tax paid of at least P100,000.
    • Gross sales of at least P10,000,000.
    • Gross purchases of at least P5,000,000.
    • Excise tax payment of at least P100,000.
  • Illustrative examples clarify computation of withholding tax on agricultural purchases exceeding threshold.

Creditable Withholding Tax on Income Payments by Top 5,000 Individual Taxpayers

  • Applies to income payments by Top 5,000 individual taxpayers engaged in trade/business or profession to their local/resident suppliers of goods and services.
  • Non-resident aliens engaged in business included.
  • Applies similarly to agricultural products exceeding P300,000 threshold per taxable year.
  • Withholding tax rates:
    • Supplier of goods: 1%
    • Supplier of services: 2%
  • Criteria for Top 5,000 Individual Taxpayers:
    • VAT payment or payable of at least P100,000.
    • Annual income tax due of at least P200,000.
    • Percentage tax paid of at least P100,000.
    • Gross sales of at least P10,000,000.
    • Gross purchases of at least P5,000,000.
    • Excise tax payment of at least P100,000.
  • For resident citizens with multiple business lines, all lines are considered.
  • For non-resident individuals, only income derived in the Philippines considered.
  • Definitions:
    • Goods: tangible personal property used in business or profession (excludes intangible and real property).
    • Local/resident supplier of goods: regular supplier, not casual, typically with at least six transactions.
    • Regular suppliers: suppliers with at least six transactions within current or previous year.
  • Single purchases of goods (non-agricultural) of P10,000 or more are subject to withholding tax.
  • The individual taxpayer becomes a withholding agent once formally notified and remains so unless notified otherwise.
  • Procedures for submitting lists of regular suppliers to the BIR twice yearly, in prescribed formats.
  • The Commissioner may amend criteria based on economic factors and conduct periodic reviews for delisting or inclusion.

Mandatory Electronic Filing and Payment

  • Top 5,000 Individual Taxpayers must file returns and remit withheld taxes through the Electronic Filing and Payment System (EFPS).
  • Compliance is pursuant to Revenue Regulations No. 9-2001 and its amendments.

Repealing Clause

  • All existing revenue regulations or issuances inconsistent with these provisions are repealed or amended accordingly.

Effectivity

  • The regulations take effect 15 days after publication in a newspaper of general circulation.

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