Tax notes: Compliant alphalists as condition for deductibility of expenses

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Tuesday, January 21, 2014

THE submission of alphabetical lists or “alphalists” where the income payments and taxes withheld are lumped into one single amount (e.g. “various employees”, “various payees,” “PCD nominees”, “Others”, etc.) shall no longer be allowed with the issuance of Revenue Regulations (RR) No. 1-2014. Such alphalists including any alphalist that does not conform to the prescribed format thereby resulting to the unsuccessful uploading into the Bureau of Internal Revenue (BIR) system shall be deemed not received and shall disqualify the deductibility of the expense for income tax purposes.

The alphalists cover those which are required to be attached in the annual information returns (BIR Forms1604CF/1604E) and monthly remittance returns (BIR Form 1601C, etc.).

Mandatory electronic submission of alphalists is now required by all withholding agents regardless of the number of employees and payees beginning Jan. 31, 2014 and March 1, 2014 alphalist filing. Thus, manual filing will no longer be allowed.


Electronic submission of the alphabetical list of employees and list of payees by all withholding agents shall be made either of the following modes:

1) Attachment in the electronic filing and payment system (eFPS);

2) Electronic submission using the BIR’s website (; and

3) Electronic mail (email) at dedicated BIR address using the prescribed CSV data file format.

Withholding agents without their own internet facility or do not have access to internet connection within their location should file their aphalists through email using the e-lounge facility of the nearest revenue district office or revenue region of the BIR.

Published in the Sun.Star Cebu newspaper on January 21, 2014.


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