Quarterly Filing of VAT under the TRAIN Law: Transition Issues

The BIR has recently issued RMC No. 5-2023 that discusses the implementation of the quarterly filing of VAT returns.

Under the said RMC, taxpayers are no longer required to file monthly VAT declaration but will instead file the Quarterly Value-Added Tax Return (BIR Form 2550Q) for transactions beginning January 1, 2023 every 25th day following the close of each taxable quarter. The RMC also provided transitory provisions for taxpayers under the fiscal period of accounting.

Example 1: Quarter ending March 31, 2023

1. The quarter ending March 31, 2023 is composed of 3 months covering the periods of January 2023, February 2023 and March 2023. The monthly VAT returns (BIR Form 2550M) for January 2023 and February 2023 are not required to be submitted under the new RMC.

2. The quarterly VAT returns for the quarter ending March 31, 2023 (BIR Form 2550Q) is required to be filed on or before April 25, 2023.

Example 2: Quarter ending February 28, 2023

1. The quarter ending February 28, 2023 is composed of 3 months covering the periods of December 2022, January 2023 and February 2023. The monthly VAT returns (BIR Form 2550M) for January 2023 is not required to be submitted under the new RMC but the VAT returns (2550M) for December 2022 is still required to be filed on or before January 20, 2022.

2. The quarterly VAT returns for the quarter ending February 28, 2023 (BIR Form 2550Q) is required to be filed on or before March 25, 2023.

Example 3: Quarter ending January 31, 2023

1. The quarter ending January 31, 2023 is composed of 3 months covering the periods of November 2022, December 2022 and January 2023. The monthly VAT returns (BIR Form 2550M) for November 2022 was already filed on December 20, 2022. The December 2022 VAT returns (BIR Form 2550M) is required to be submitted on January 20, 2023 under the new RMC.

2. The quarterly VAT returns for the quarter ending January 31, 2023 (BIR Form 2550Q) is required to be filed on or before February 25, 2023.

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RMC No. 5-2023.pdf

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