In addition to Large and Top 20K taxpayers, BIR identified additional top withholding agents in Revenue Regulations (RR) 11-2018.
First things first, let us understand medium and TAMP taxpayers. Medium taxpayers are the top 500 non-individual taxpayers of the 12 revenue regions that satisfy the criteria for large taxpayers but have not been notified by the Commissioner of Internal Revenue as such as prescribed in RMO 17-2017. While TAMP is a program in BIR that aims to enhance voluntary tax compliance of taxpayers through assigning specific taxpayers to revenue officers to monitor and analyze compliance through benchmarking. Any exceptions noted especially taxpayers having financial and tax trends under a set benchmark can become subject for audit, surveillance, etc.
In RR 11-2018 dated January 31, 2018, medium taxpayers and those under TAMP are now considered as top withholding agents in addition to Large Taxpayers and Top 20K corporations.
What does it mean when a taxpayer is considered a top withholding agent? This means that in addition to withholding to contractors/subcontractors, professionals, lessors, etc., you now need to withholding in all of your purchase of goods and services.
The BIR will release a publication in a newspaper of general circulation to identify medium and taxpayers under TAMP (though there are instances that BIR will also issue a formal notice to medium taxpayers). It may also be posted in the BIR website. This will serve as notice to the top withholding agents. The obligation to withhold shall commence on the first (1st) day of the month following the month of publication.
Medium taxpayers and those under TAMP are still under the jurisdiction of their RDO. So any filing requirements will be done at RDO level.
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Disclaimer: The views or opinions in this article are mine. This is not a substitute for seeking professional advice.
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