Annual Inventory List, BIR Form No. 2316
Ref= BIR memo
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Notes from the net:
1. https://cloudcfo.ph/blog/taxes/inventory-lists-in-the-philippines-explained
UPDATED 2023: BIR Inventory Lists in the Philippines
Do you run a business in the Philippines? Does the business hold inventories for commercial sale? If so, are you aware of the key BIR compliance requirement to submit updated Inventory Lists to the BIR each year?
In short – businesses in the Philippines that hold inventories for sale are required to submit an updated Inventory List to the BIR by a specific deadline every year.
Our Explainer below outlines all you need to know about the submission of BIR Inventory Lists!
We also outline the Deadline Date for the submission of the Inventory List by PH companies in 2023!
What is the Inventory List?
The Inventory List is a compliance requirement for businesses that hold inventory for sale in the Philippines. This list must be prepared and submitted by relevant companies to the BIR on an annual basis.
The Inventory List is a comprehensive report that must outline the details of all inventories held by a company as at the last date of the company’s financial year.
The Deadline Date for submission each year depends on the financial year (i.e. calendar or fiscal) of the particular business. Many companies in the Philippines will have financial years that follow the calendar year. This means that the last date of the financial year for many businesses will be 31 December.
See further below for the submission Deadline Date that applies to your business!
It’s important to note that the Inventory List is not the only inventory-related document or record that has to be submitted to the BIR at the time of submitting the Inventory List! The BIR requires other inventory-related documents, records and schedules to be submitted along with the Inventory List – as outlined further below!
Why Must PH Companies Submit an Inventory List?
The primary reason for submitting an Inventory List in the Philippines is simple – it’s a mandatory compliance requirement under the Philippine tax and compliance framework. That is as good a reason as any reason!
Section 13 of Revenue Regulations No. V-1, also known as the Bookkeeping Regulations, provide that taxpayers in the Philippines that hold inventories for sale are required to have and maintain a book of inventories.
RR No. V-1 also requires that details relating to such inventories held at the end of each financial year by a company must be prepared and submitted to the BIR.
If you don’t have robust inventory management processes or systems in place, completing the Inventory List accurately can sometimes be quite a challenge!
One of our previous articles might be quite helpful in this regard as we identify a number of inventory management controls that can help your PH business and make the submission of BIR Inventory Lists each year a much more efficient process!
What Information Must be Included in the Inventory List?
RR No. V-1 provides that the Inventory List should include various details relating to the type, value and number of inventories held by a company.
Under RR No. V-1, the following information should be provided in relation to all inventories for sale which are held by a company on the last date of the previous financial year:
- A Description of the goods or inventories held by the company;
- The Quantity of the goods or inventories held;
- A Description of the particular types of inventories held by the business;
- The Unit in which the inventory is measured or valued by the business;
- The Total Cost of every item of stocks-in-trade, materials, supplies and other goods found on the premises of the company at the close of the financial year.
What Can Be Excluded From the Inventory List?
Inventories that are not held for sale are not required to be included in the Inventory List.
Why would a company hold inventories or stocks of a product that are not actually for sale?
Businesses will usually have items that they hold which might help them to run their business operations but are not necessarily part of the goods that are sold to customers.
This might include, for example, spare parts for machines, daily office supplies, IT equipment for internal use by company representatives or employees, manufacturing supplies and any other equipment or items that are required to support the internal operations of a company.
It’s Important to Know What to Include in the Inventory List!
Submitting the Inventory List to the BIR with accurate details and information is an important exercise!
Why? Here are just a few reasons:
- Double reporting – Sometimes, two companies might include the same inventory in each of their Inventory Lists. For example, consigned goods might incorrectly appear in the inventory lists of both the consignor and the consignee. So it would be practical for the consignor and consignee to communicate and settle any potential discrepancies that might arise within their respective Inventory Lists.
- Incorrect information in the Inventory List may result in inaccurate information being recorded in the accounting records/books, inaccurate budgets and forecasts as well as incomplete financial reports.
- The submission of incorrect information to the BIR can result in financial penalties (see further below).
- Inaccurate reporting of inventory can give rise to investigations or audits by the BIR.
Above are just 4 key reasons for why companies need to ensure their Inventory Lists are accurate and submitted on time! There are undoubtedly many more reasons.
So make sure to treat the BIR Inventory List as any other type of tax or compliance requirement here in the Philippines and get your Inventory Lists filed on time every year!
But, My Business Does Not Have Any Inventories at the End of the Year?
Ok – But, does the business usually hold inventories for sale? If so, then an Inventory List will still have to be filed!
If your company usually holds inventory, but, for some reason, it just did not have any inventories at the end of the prior financial year, the company is still required to submit an Inventory List – it just won’t include any details of any inventories held!
Why would a company not have inventories at the end of the financial year if it is a company that sells goods as a commercial business? This could arise for a number of reasons!
Perhaps, the company stopped operating for a few months due to the current Covid pandemic and as a result, stopped purchasing stocks or inventories. Perhaps, the current global supply chain challenges affected the company’s inventories and a new shipment of goods is not due until the following year. Or perhaps, simply, the end of the financial year fell at a time at which stocks had been depleted and the new stocks had not yet arrived!
The reasons are endless. However, the important thing to remember from a compliance perspective, is that if your company usually holds inventories for sale to customers, you will have to consider the submission of the Inventory Lists every year – whether or not you actually have inventories on hand at the end of the year!
What is the Deadline for Submitting the Inventory List?
Inventory Lists must be submitted every year. The Inventory List Deadline in the Philippines is within 30 days of the end of the company’s financial year.
So, as mentioned above, the submission date for each company can vary depending on the date of the company’s financial year.
Many companies will have a financial year that follows the regular calendar year, meaning 1 January – 31 December. However, some companies might select a different financial year (also referred to as a fiscal year).
Why might a company choose a financial year that differs from the calendar year? There could be many reasons for this – there is generally no specific formula.
For example, the Philippine company might be a subsidiary and part of a larger group of companies, either internationally or domestically, which follow a different financial year. Management will generally want all group companies to have the same financial year. Or perhaps management wanted to align the financial year with the registration of the business – i.e. if the business was registered on 1 June, management might like to keep the financial year as 1 June to 31 May.
Here’s an example to help companies understand and prepare for the Inventory List Deadline!
In the example below, the financial year of ABC Company follows the calendar year, while XYZ Company and PPP Company follow their own fiscal years.
As a result, the deadlines for the submission of annual Inventory Lists are different, as outlined below:
| Company Name | Financial Year | End of the Financial Year | Deadline for Submission of Annual Inventory List |
| ABC Company | Calendar Year | December 31, 2022 | January 30, 2023 |
| XYZ Company | Fiscal Year | June 30, 2023 | July 30, 2023 |
| PPP Company | Fiscal Year | September 30, 2023 | October 30, 2023 |
Additional Reporting Requirements
In 2015, the BIR issued Revenue Memorandum Circular No. 57-2015, which provided further guidelines on the submission of the BIR Inventory List and additional information that must be submitted along with the Inventory List.
Certain companies are required to submit various records, lists and schedules in addition to the Inventory List.
This includes companies that maintain inventory of stock-in-trade, raw materials, goods in process, supplies and other goods, such as manufacturing, wholesaling, distributing/retailing sectors, real estate dealers/developers and service companies, e.g., construction companies, building contractors, etc.
Under RMC No. 57-2015, a business with tangible asset-rich balance sheets with at least half of its total assets in working capital assets (e.g. accounts receivable, inventory), must submit, in both hard and soft copy, additional schedules and lists in the prescribed format outlined in the Annexes to RMC No. 57-2015, as follows:
- For manufacturing, merchandising or retail companies – inventory of merchandise/raw materials/goods in process/finished goods (Annex A)
- For real estate companies – inventory of saleable units with corresponding cost per project (Annex B) and/or inventory of saleable units per project with the corresponding trade accounts receivable reconciliation (Annex B-1)
- For construction industries – schedule of outstanding receivables (beginning and ending) and realized gross profit per project (Annex C)
What about the soft copies of these records?
The soft copies of the Inventory List and the additional schedules and reports must be submitted via an accurately labeled DVD-R, along with a Notarized Certification signed by the authorized representative of the taxpayer. This Certificate is to certify that the information contained on the DVD-R is true and accurate.
A template format for this Certificate can be found at Annex D of RMC No. 57-2015.
Penalties
Companies must recognise the filing of the BIR Inventory List as a key compliance requirement under the Philippine tax and compliance framework!
Where a company does not file the Inventory List by the relevant Deadline Date, or files the Inventory List using an incorrect format or without the required accompanying documents and records (in other words, filing in a format not-prescribed by the BIR), the company will be in breach of its BIR filing obligations and will be subjected to penalties for non-filing.
Section 3 of RMC No. 57-2015 outlines the penalties for violations of the requirement to submit both the Inventory List and the additional reporting documents, records and schedules.
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