BIR Form 1604-E – Annual Information Return of Creditable Income Taxes Withheld (Expanded)

A BIR Form 1604-E – Annual Information Return of Creditable Income Taxes Withheld (Expanded) in the Philippines reports the income, deductions and tax due to the revenue authority for the period it covers.

BIR Form 1604-E serves as the annual reconciliation document that allows the BIR to verify whether all EWT collected by the withholding agent throughout the year has been fully remitted. The return must be accompanied by an Alphabetical List of Payees (known as the Alphalist of Payees Subject to Expanded Withholding Tax) — a detailed schedule listing every payee from whom EWT was withheld, organized alphabetically, showing each payee's TIN, registered name, nature of income payment, ATC code, total amount paid, and EWT withheld during the year.

The Alphalist of Payees submitted with BIR Form 1604-E is the primary source document the BIR uses to cross-match with payees' individual income tax returns (BIR Form 1701 or 1702), verifying that the EWT credits claimed by payees in their ITRs match the amounts actually withheld and remitted by their payors. Discrepancies between the Alphalist and payee ITRs are a common trigger for BIR audit selection.

BIR Form 1604-E was introduced under BIR Revenue Regulations No. 2-98 (as amended) and further standardized by BIR Revenue Regulations No. 11-2018 (implementing the TRAIN Law). Large taxpayers file BIR Form 1604-E electronically through the eFPS; non-large taxpayers use the eBIRForms system. The Alphalist must be submitted in the prescribed CSV or XML format through the BIR Data Entry Module.

The legal framework governing the BIR Form 1604-E – Annual Information Return of Creditable Income Taxes Withheld (Expanded) in Philippines draws on several key statutes and regulatory bodies. Under Philippine law, the Civil Code of the Philippines (Republic Act No. 386) governs contractual obligations. The Revised Corporation Code (Republic Act No. 11232) regulates corporate entities through the Securities and Exchange Commission (SEC). The Labor Code of the Philippines (Presidential Decree No. 442) and Department of Labor and Employment (DOLE) govern employment matters. The Data Privacy Act of 2012 (Republic Act No. 10173) and the National Privacy Commission (NPC) protect personal data. The Bureau of Internal Revenue (BIR) administers tax obligations under the National Internal Revenue Code. Parties executing a BIR Form 1604-E – Annual Information Return of Creditable Income Taxes Withheld (Expanded) in Philippines should confirm the document reflects current law, including any amendments enacted since the original drafting date. The National Internal Revenue Code (RA 8424) sets the foundational requirements.

BIR Form 1604-E must be filed annually by January 31 by every withholding agent in the Philippines that withheld and remitted EWT during the preceding calendar year.

BIR Form 1604-E is required for a corporation that paid professional fees, rental income, contractor payments, or commissions to individuals and companies subject to EWT throughout the year — the annual return consolidates all the monthly BIR Form 0619-E and quarterly BIR Form 1601-EQ remittances into a single annual reconciliation with the Alphalist of Payees.

BIR Form 1604-E is required for Top Withholding Agents (TWAs) designated by the BIR under BIR Revenue Regulations No. 12-2020 that withheld 1% EWT on goods purchases and 2% EWT on services from all local suppliers — the annual return must include every supplier from whom the TWA withheld EWT, documented in the Alphalist.

BIR Form 1604-E is required for property owners and businesses that withheld 5% EWT on rent payments to landlords — even if EWT was withheld only for part of the year, an annual return covering the months of withholding must be filed.

BIR Form 1604-E is required for government agencies, GOCCs, and LGUs that withheld EWT on payments to suppliers under Section 2.57.2(M) of BIR Revenue Regulations No. 2-98 — procurement payments to private sector vendors are subject to EWT and must be reported annually.

BIR Form 1604-E is required even when the EWT withheld during the year was already fully remitted through the monthly and quarterly returns — the annual return confirms complete remittance and provides the Alphalist data for payee cross-matching.

Parties in Philippines should prepare a BIR Form 1604-E – Annual Information Return of Creditable Income Taxes Withheld (Expanded) proactively rather than waiting for a dispute to arise. Courts interpret agreements based on the written terms rather than oral representations. Under Philippine law, the Civil Code of the Philippines (Republic Act No. 386) governs contractual obligations. The Revised Corporation Code (Republic Act No. 11232) regulates corporate entities through the Securities and Exchange Commission (SEC). The Labor Code of the Philippines (Presidential Decree No. 442) and Department of Labor and Employment (DOLE) govern employment matters. The Data Privacy Act of 2012 (Republic Act No. 10173) and the National Privacy Commission (NPC) protect personal data. The Bureau of Internal Revenue (BIR) administers tax obligations under the National Internal Revenue Code. Where the transaction involves regulated activities, prior approval from the relevant authority may be required before execution.

A complete BIR Form 1604-E for the Philippines must include the following components for accurate annual EWT reporting.

Withholding Agent Information: Full registered name, TIN, RDO number, and complete business address of the withholding agent. For entities with multiple branches, the head office files a consolidated BIR Form 1604-E unless branch-level filing is required by the RDO.

Annual Period Covered: Calendar year (January 1 to December 31) for which EWT was withheld. BIR Form 1604-E covers only the calendar year period — fiscal year filers still report on the calendar year basis for withholding tax purposes.

Summary of EWT by ATC Code: For each Alphanumeric Tax Code, report the total income payments made during the year and the total EWT withheld. The ATC-level summary must match the aggregate Alphalist data and the sum of monthly/quarterly remittances.

Total EWT Withheld and Remitted: The aggregate EWT remitted via BIR Form 0619-E (8 months) and BIR Form 1601-EQ (4 quarters). Any discrepancy between the annual total and the sum of monthly/quarterly remittances must be explained and settled with a supplementary payment.

Alphalist of Payees (Schedule): The mandatory alphabetical list of all payees from whom EWT was withheld, filed as a separate attachment in BIR-prescribed CSV/XML format through the Data Entry Module. Each Alphalist entry must state: payee TIN, payee registered name, nature of income payment, ATC code, gross amount paid, EWT rate, and EWT withheld. BIR Form 2307 (Certificate of Creditable Tax Withheld at Source) must be issued to each payee on the Alphalist by January 31 — or within 20 days after the close of each quarter for quarterly issuance.

Electronic Filing: BIR Form 1604-E must be filed electronically through eFPS (large taxpayers) or eBIRForms (all others) under BIR Revenue Memorandum Circular No. 49-2016. Manual filing is no longer accepted for this return.

Additional compliance elements for a BIR Form 1604-E – Annual Information Return of Creditable Income Taxes Withheld (Expanded) used in Philippines include: Under Philippine law, the Civil Code of the Philippines (Republic Act No. 386) governs contractual obligations. The Revised Corporation Code (Republic Act No. 11232) regulates corporate entities through the Securities and Exchange Commission (SEC). The Labor Code of the Philippines (Presidential Decree No. 442) and Department of Labor and Employment (DOLE) govern employment matters. The Data Privacy Act of 2012 (Republic Act No. 10173) and the National Privacy Commission (NPC) protect personal data. The Bureau of Internal Revenue (BIR) administers tax obligations under the National Internal Revenue Code. Forms-legal.com provides this template as a starting point for Philippines-compliant documentation.