Allowed to Skip BIR Form 2307 Filing Without Purchases in the Philippines

Executive summary

BIR Form 2307 (“Certificate of Creditable Tax Withheld at Source”) is not a tax return filed with the Bureau of Internal Revenue (BIR). It is a certificate that proves that creditable withholding tax (CWT) was deducted from a payee’s income.

If you made no payments subject to CWT during a period (e.g., you had “no purchases” from suppliers/payees subject to expanded withholding), you will not have any Form 2307 to issue.
If you received no income subject to CWT (e.g., none of your customers withheld from you), you will not have any Form 2307 to collect or attach to your own return.
Separately, your obligation to file withholding tax returns (e.g., 0619-E/0619-F, 1601-EQ, 1601-FQ, annual 1604-E/1604-F) depends on whether you are registered/required as a withholding agent; some filers must still submit “no-payment” returns even for nil periods. That is a different compliance track from Form 2307 itself.

This article explains the legal nature of Form 2307, when you may skip issuing/collecting it, and the adjacent filing and documentation rules that commonly get confused with the certificate.

What BIR Form 2307 is—and isn’t

What it is: A document of proof issued by a withholding agent (payor) to the income recipient (payee) showing creditable tax withheld from payments (e.g., professional fees, rentals, contractor payments, purchases of services, certain goods). The payee later uses the certificate to claim the withheld amount as a tax credit against quarterly/annual income tax.
What it is not:
- It is not the tax remittance/return—those are 0619-E/0619-F (monthly remittances) and 1601-EQ/1601-FQ (quarterly withholding returns), plus annual information returns (1604-E/1604-F).
- It is not filed with the BIR on a periodic schedule. It is prepared, issued, and retained; the amounts it evidences flow into returns and alphalists.

Legal positioning: roles and obligations

1) If you are a withholding agent (payor)

Issue Form 2307 only when you actually withhold CWT.
- If you made no payments subject to CWT for the period (e.g., literally no purchases of services or other CWT-covered items), you do not issue any 2307 because there is nothing to certify.
File the relevant returns even for nil periods, if required.
- If your registration and BIR enrollment designate you as a withholding agent (e.g., “Withholding Tax – Expanded”), you may be required to file “no-payment” monthly/quarterly returns for periods with no transactions. This requirement comes from the withholding return rules, not from Form 2307.
QAP/alphalist interaction.
- When you file 1601-EQ for a quarter in which you had payments and withheld tax, you must submit a Quarterly Alphalist of Payees (QAP). If there were no payees/no withholding, the QAP is generally not populated; the return may still be submitted as no-payment per your filing profile.

2) If you are a payee (income recipient)

Collect Form 2307 only when your customer withheld from you.
- If no one withheld from your income during the period, you won’t have a 2307 to collect and you cannot claim a CWT credit for that period.
Income tax filings (quarterly/annual).
- You may file your ITR without attaching SAWT/2307 details if you are not claiming any CWT credit (because there is none).
- If you do have 2307s, you must encode/attach details (e.g., through SAWT schedules) to claim the credit.

“No purchases” scenarios: can you skip 2307?

Scenario	2307 issuance/collection	Withholding returns	Notes
You are a payor; this month you had no CWT-covered purchases	No 2307 to issue	Still file “no-payment” returns if your profile requires	Consider deregistering as withholding agent if never applicable
You are a payee; you made no sales or no one withheld from your income	No 2307 to collect	Not applicable (you are not filing withholding returns as a payee)	You cannot claim any CWT credit in your ITR
You are a payor; purchases were made but not subject to CWT (e.g., from VAT-registered supplier of goods where no EWT applies)	No 2307 to issue for those payments	File returns reflecting no withholding for the period, if required	Ensure correct classification—many service payments are CWT-covered
You are a payor; you should have withheld but did not	You should have issued 2307	You must file/ammend, remit tax plus penalties	Non-withholding when required triggers surcharge, interest, compromise

Practical tests to decide

Was there a payment to a person/entity that is CWT-covered?
- If no, there is no 2307 to issue.
- If yes, you likely withhold and issue 2307.
Are you registered/considered a withholding agent for EWT or FWT?
- If yes, expect to file returns on their prescribed schedules, sometimes even when nil.
- If you consistently have no CWT-covered transactions, discuss registration update with your RDO to remove the withholding tax obligation (reduces “no-payment” filings).
Are you trying to claim a CWT credit on your ITR?
- You must possess matching 2307s (or duly recognized digital equivalents) and encode them in the schedules.

Documentation & timing

Issuance to payees: Payors typically release Form 2307 per payment or per periodic cut-off (e.g., monthly/quarterly), after remitting the tax.
Retention: Both parties keep copies under the books and records retention rules.
Digital processes: If you operate in eBIRForms/eFPS/eAFS ecosystems or e-invoicing pilots, ensure the digital rendition of the 2307 contains the required fields (TINs, nature of payment/ATC, base amount, tax rate, tax withheld, period).

Common pitfalls

Confusing Form 2307 with returns. Skipping a withholding return because you had “no purchases” can still be a compliance violation if you are registered as a withholding agent.
Wrong assumption that goods are never CWT-covered. Some purchases of goods can be covered when paid to certain suppliers/contractors under particular ATCs; always map the nature of payment to the applicable withholding rule.
Claiming CWT credit without certificates. Audits often disallow credits lacking properly accomplished 2307s (or duly accepted substitutes).
Using supplier’s 2307 to support your own claim. Only 2307s where you are the named payee support your tax credits.

Compliance strategies

Map your spend types (professional fees, rentals, subcontracting, commissions) to applicable ATCs and rates; keep a simple matrix and update it as rules change.
Set “nil-month” workflows. Even when there are no transactions, have a checklist: prepare “no-payment” returns if applicable; no QAP if there are no payees; no 2307 to issue.
Supplier onboarding. Get suppliers’ TINs and registration details up front; this avoids late withholding and late 2307 issuance when purchasing resumes.
Registration hygiene. If you never make CWT-covered payments (e.g., a holding company with no local operating spend), explore removing the EWT registration to eliminate recurring nil filings.
Year-end tie-out. Reconcile: (a) 2307s you issued vs. withholding returns/QAP; (b) 2307s you received vs. CWT credits claimed in your ITR.

Answers to specific, frequent questions

Q: We had zero purchases this quarter. Can we skip Form 2307 entirely? A: Yes, no 2307 to issue. But if you are a registered withholding agent, you likely still need to file a no-payment 1601-EQ (and 0619-E for months in the quarter) to show no withholding occurred.
Q: Our customers didn’t withhold from us this year. Do we need to attach 2307s to our annual ITR? A: No. No 2307 means no CWT credit to claim; file the ITR without those attachments/schedules.
Q: We accidentally failed to withhold and therefore have no 2307 to issue. What now? A: Withhold and remit retroactively via amended returns, settle surcharge/interest/compromise, and then issue the late 2307 to the payee.
Q: Is there a penalty for not issuing 2307 when there were no CWT payments? A: No, because issuance is transaction-driven. Penalties arise from non-filing of required returns or failure to withhold when required, not from the absence of a certificate where no withholding occurred.

Takeaways

Form 2307 is only created when there is actual CWT withheld.
No purchases/no CWT = no 2307 to issue or collect.
Withholding returns and alphalists are separate obligations that may still apply in nil periods, depending on your registration.
If “no purchases” is a recurring fact pattern, consider a registration update to remove unnecessary withholding obligations.

This article reflects general Philippine tax compliance principles. Specific obligations can vary by taxpayer profile and may be affected by subsequent BIR issuances. When in doubt, review your registration status and your most recent return instructions, or consult your RDO/tax adviser for an engagement-specific check.