Republic of The Philippines Department of Finance Bureau of Internal Revenue
Republic of The Philippines Department of Finance Bureau of Internal Revenue
Republic of The Philippines Department of Finance Bureau of Internal Revenue
DEPARTMENT OF FINANCE
BUREAU OF INTERNAL REVENUE
SUBJECT:
TO:
The Bureau of Internal Revenue (BIR), in its mission of providing an efficient and
convenient service to its taxpayers, is implementing a hassle-free method of filing
Individual Income Tax Returns (BIR Form 1700). This method of filing recognizes
under certain circumstances, the employers Annual Information Return (BIR Form No.
1604CF) as the substitute income tax return filed by the employee since it contains the
same information found in the income tax return ordinarily filed.
This Circular aims to provide some basic information and answers to questions
frequently asked on substituted filing.
1. What is Substituted Filing?
Substituted Filing is when the employers annual return (BIR Form 1604CF) may
be considered as the substitute Income Tax Return (ITR) of employee inasmuch
as the information provided in his income tax return (BIR Form 1700) would
exactly be the same information contained in the employers annual return (BIR
Form No. 1604-CF).
2. How is Substituted Filing different from Non-Filing?
Under substituted filing, an individual taxpayer although required under the law
to file his income tax return, will no longer have to personally file his own income
tax return but instead the employers annual information return filed will be
considered as the substitute income tax return of the employee inasmuch as the
information in the employers return is exactly the same information contained in
the employees return.
b.
c.
d.
e.
The amount of tax due from the employee at the end of the year
equals the amount of tax withheld by the employer
If married, that the employees spouse also complies with all three (3)
conditions stated above.
That the employee has none of the instances for disqualification for
substituted filing. (refer to question no. 4 of this issuance)
That the BIR Form 1604CF filed by his employer shall constitute as his
income tax return
That BIR Form 2316 (Oct 2002 ENCS version) shall serve as the same
purpose as if BIR Form 1700 had been filed pursuant to the provisions of RR
3-2002 as amended by RR 19-2002.
12. For other government agencies and other offices, public and private,
requiring presentation of individual income tax return (BIR Form 1700) as
proof of income earnings, what would be a replacement for BIR Form 1700
for those qualified for substituted filing?
For those qualified for substituted filing, BIR Form 1700 should no longer be
required as proof of financial capacity or proof of income earnings. Presentation
of BIR Form 2316 (Oct 2002 ENCS version) is sufficient proof of income
earnings since it is a statement signed by both the employee and the employer and
it shall serve the same purpose as if BIR Form No. 1700 had been filed.
13. What is the use of the BIR Form 2316, for those qualified for substituted
filing?
The BIR Form 2316 (Oct 2002 ENCS version) can be used for the following
purposes:
a. As proof of financial capacity for purposes of loan, credit card, or other
application
b. As proof of payment of tax or for availing tax credit in the employees
home country
c. In securing travel permits and travel tax exemptions when necessary; and
d. For other purposes to meet the requirements of various
government/private agencies
14. When does substituted filing take effect?
It took effect for taxable year 2001 on a voluntary basis and is mandatory for
income/compensation earned starting taxable year 2002. Thus, employees who
qualify for substituted filing for taxable year 2002 and beyond will no longer file
BIR Form 1700 on or before the 15th of April of every year.
15. What will an employee do with BIR Form 2316 issued by the employer?
If the BIR Form 2316 was issued by a previous employer as a result of
termination of employment and the employee has been subsequently employed
within the same calendar year, the employee should submit a copy of BIR Form
2316 issued by the previous employer to his present employer, for consolidation
with his current compensation received from the present employer.
If the employee is qualified for substituted filing, the employee concerned should
sign the substituted filing signature box of BIR Form 2316 and have the same
signed by the employer. A copy of BIR Form 2316 signed both by the employer
and employee shall be retained and kept by the employer and the employee.
If an employee is not qualified for substituted filing, he is required by law to file
his income tax return (BIR Form 1700 or BIR Form 1701). BIR Form 2316
should be attached as proof of his compensation income and withholding taxes as
well as other necessary and applicable attachments, like financial statements,
certificate of creditable withholding taxes.
16. For those qualified for substituted filing, is it necessary to have BIR Form
2316 notarized?
No, it is not necessary to have BIR Form 2316 notarized for those qualified for
substituted filing.
17. Can an employee file an ITR (BIR Form No. 1700) even if he is qualified for
substituted filing?
No, for taxable year 2002 and beyond, substituted filing is mandatory for
qualified employees.
(Original Signed)
GUILLERMO L. PARAYNO, JR.
Commissioner of Internal Revenue