Post-filing reminders

Post-filing reminders

by Shirley S. Go

"Yes!" was the first word I uttered upon learning that the last return I was responsible for filing had been received by the Bureau of Internal Revenue (BIR). After months of hard work which had included sleepless nights, the day for filing ITR had finally arrived and I am grateful that we had filed them all.

However, just like in surgical procedures, accountants need to do post-surgery or post-filing procedures/reports. There are a number of reports that need to be filed with other regulatory agencies as well.

Let me share with you my list of my post-filing procedures/reports.

1.  Electronic Filing and Payment System (EFPS) filers — A taxpayer who has filed his annual income tax return through the EFPS is required to submit to the BIR office where he/she is registered within 15 days from date of e-filing his/her return, an annual return (Form 1702) with the tax due correctly computed, together with the Filing Reference Number Page. Together with the return, the taxpayer must file his/her audited financial statements, copies of creditable withholding taxes (BIR Form 2307) supporting the creditable taxes claimed in the return and other required documents.

2. Philippine Economic Zone Authority (PEZA) — Corporations registered with the PEZA must comply with certain requirements to avail of the tax incentives granted to them under RA 7916. PEZA enterprises must submit to PEZA copies of their annual income tax return (BIR FORM 1702) within 15 days from filing with the BIR and their Audited Financial Statements within 30 days after filing with the BIR.

3. Board of Investments (BoI) — Under Executive Order No. 226, a corporation registered with the BoI must also file certain returns in order to avail of its incentives. In the case of BoI-registered firms under income tax holiday (ITH), they must file an application for ITH on or before a month after the filing of their final ITR with the BIR. The application must be duly notarized and submitted together with the required documents, which include, among others, the completed Income Tax Return together with the computation of taxable income per ITR/application in case there are no details on the reconciling items; gross interest income subjected to final tax for purposes of computing non-deductible interest expense; breakdown of miscellaneous income, if any. They are likewise required to submit:

• the audited Financial Statements
  
• the audited segregated income statement of registered and non-registered activities
  
• in case of multi-registered activities, segregated audited income statement for each of the registered activities
  
• breakdown of miscellaneous/other/various income, if amount are different per ITR
  
• details of scrap sales, if any, and
  
• summary sales.

In case the company is availing of the ITH for the first time, it must also submit:

• a Sworn Statement signed by the authorized representative on the actual start of commercial operation of a registered activity, and
• the BoI Certificate of Registration showing ITH entitlement per Specific Terms and conditions.

4. Securities and Exchange Commission (SEC) — In addition to the obligation to the BIR, taxpayers also have to comply with the requirements of the SEC. Listed companies and corporations whose securities are registered under the Revised Securities Act or Securities Regulation Code are required to submit to the SEC a copy of their Audited Financial Statements (AFS) duly stamped received by the BIR on the 105th day after the end of their fiscal year. For other corporations/companies, their AFS are due at the SEC 120 days from the end of the fiscal year. In addition, there is a requirement to file the General Form of Financial Statements (GFFS) in electronic format and this is due 30 days from the due date of the AFS.

5. Tax compliance review — It may hap pen that there were adjustments made by either the Company or its auditor during the audit. These adjustments may not have been considered when the Company filed the required withholding taxes, percentage taxes or value-added tax returns last January. It is thus advisable for the Company to do an analysis or a review of the effect of these adjustments on the other tax returns it had filed.

Take note that all these reports are important and should always be diligently prepared.

Failure to submit these reports or even delays in the submission thereof, would certainly result in penalties from the regulatory agency.

It is also necessary that due attention and care be exerted in ensuring that the reports are complete and accurate since these reports are also used by the BIR as external sources of relevant information during their tax examinations.

I can’t wait to finish this list as the sun and the beach await me in my much-needed vacation.

(The author is a tax manager at Punongbayan & Araullo, a member firm within Grant Thornton International Ltd. For comments and inquiries, please e-mail the author or call 886-5511.)