Yes. Purchases from non-VAT suppliers may be included in the Summary List of Purchases, but they should not be treated as VATable purchases and should not generate input VAT. For a VAT-registered buyer in the Philippines, the usual treatment is to report the purchase under exempt purchases or the appropriate non-VAT category, with zero creditable input tax. The practical issue is not whether the supplier is VAT or non-VAT; it is whether the purchase is a legitimate business purchase, properly documented, correctly classified, and reconciled with the VAT return, books, and purchase records.

Direct Answer: Can Non-VAT Supplier Purchases Be Included in the Summary List of Purchases?

Yes, non-VAT supplier purchases can be included in the Summary List of Purchases or SLP.

The legal reason is straightforward: the BIR’s Summary List of Purchases is not limited only to VATable purchases. Under the VAT regulations, the Quarterly Summary List of Local Purchases and Input Tax must include supplier details and categories such as exempt purchases, zero-rated purchases, purchases subject to VAT, creditable input tax, and non-creditable input tax. The same rule expressly states that the purchase schedule “shall not only refer to purchases subject to VAT but also to exempt and zero-rated purchases.” (Bir CDN)

This means a VAT-registered taxpayer should not automatically exclude a supplier just because the supplier is non-VAT. What matters is the correct classification:

Type of purchase	Include in SLP?	Where it usually goes	Can you claim input VAT?
Purchase from VAT-registered supplier with valid VAT invoice	Yes	Purchases subject to VAT	Yes, if all legal requirements are met
Purchase from non-VAT supplier or percentage taxpayer	Yes	Exempt purchases / non-VAT category	No
Purchase of VAT-exempt goods or services	Yes	Exempt purchases	No
Zero-rated local purchase	Yes	Zero-rated purchases	Usually no output VAT charged; treatment depends on transaction
Importation	Yes, but under importation schedule, not ordinary local purchase list	Summary List of Importations	VAT paid to BOC may be input VAT if properly supported
Services from non-resident foreign supplier	Special handling	Usually supported by BIR Form 1600 and withholding VAT documents	Depends on VAT withholding and substantiation rules

The most common mistake is encoding a non-VAT supplier purchase as a VATable purchase and claiming 12% input VAT. That is risky. A non-VAT supplier cannot pass on VAT because it is not VAT-registered.

What the Summary List of Purchases Is For

The Summary List of Purchases forms part of the BIR’s VAT matching system. It helps the BIR compare what a buyer reports as purchases against what suppliers report as sales.

In practice, accountants often refer to this as part of the SLSP or SLSPI:

SLS – Summary List of Sales
SLP – Summary List of Purchases
SLI – Summary List of Importations
SLSPI – Summary List of Sales, Purchases, and Importations

Under Revenue Regulations No. 1-2012, the BIR made the quarterly submission of Summary Lists of Sales and Purchases mandatory for persons liable for VAT, amending Section 4.114-3 of Revenue Regulations No. 16-2005. (Supreme Court E-Library)

The Summary List of Purchases is not a separate tax in itself. It is a reporting attachment or data file that supports the figures in the VAT return, especially BIR Form No. 2550Q, the Quarterly Value-Added Tax Return.

Legal Basis: Why Non-VAT Purchases Are Reportable but Not Creditable

1. The SLP includes exempt and zero-rated purchases

The strongest basis is Section 4.114-3 of Revenue Regulations No. 16-2005, as amended. The regulation lists the information required in the Quarterly Summary List of Local Purchases and Input Tax, including:

BIR-registered name of the seller, supplier, or service provider
Address of the seller, supplier, or service provider
TIN of the seller
Exempt purchases
Zero-rated purchases
Purchases subject to VAT
Creditable input tax
Non-creditable input tax (Bir CDN)

The same regulation clarifies that the purchase schedule is not only for VATable purchases but also for exempt and zero-rated purchases. (Bir CDN)

That is why a purchase from a non-VAT supplier is not “invisible” for SLP purposes. It may still be part of the buyer’s total business purchases.

2. Input VAT generally requires a VAT-registered supplier

Input tax is the VAT due from or paid by a VAT-registered person on importation or on local purchases from a VAT-registered person. The BIR’s own guidelines for BIR Form 2550Q define input tax as VAT due from or paid by a VAT-registered person on importation or local purchase of goods or services from a VAT-registered person. (Bir CDN)

So if your supplier is non-VAT, there is generally no input VAT to claim.

Example:

A VAT-registered restaurant buys vegetables from a small non-VAT supplier for ₱50,000. The supplier issues a non-VAT sales invoice.

Correct treatment:

Purchase amount: ₱50,000
SLP classification: exempt purchase / non-VAT purchase category
Creditable input VAT: ₱0
Do not divide by 1.12
Do not compute 12% input VAT

3. Non-VAT suppliers may be percentage taxpayers

Many non-VAT suppliers are small businesses whose gross sales do not exceed the VAT threshold or whose transactions are exempt under Section 109 of the National Internal Revenue Code. Under the Ease of Paying Taxes Act, Republic Act No. 11976, a person whose sales are exempt under Section 109(CC) and who is not VAT-registered pays percentage tax under Section 116, generally at 3% of gross quarterly sales, subject to the law’s specific rules. (Lawphil)

That means the supplier may still be a legitimate BIR-registered taxpayer even if it is non-VAT. The buyer should still require a proper invoice.

How to Classify Non-VAT Supplier Purchases in the SLP

For ordinary local purchases from non-VAT suppliers, the safest practical approach is:

Include the supplier in the SLP if the purchase is part of your business purchases for the VAT quarter.
Use the supplier’s BIR-registered name, TIN, and address as shown in the invoice or BIR records.
Report the purchase under exempt purchases or the corresponding non-VAT purchase field in the BIR module or accounting system.
Put zero in creditable input tax.
Do not treat the purchase as “purchases subject to VAT.”
Reconcile the SLP total with your purchase book, general ledger, and BIR Form 2550Q.

The key point is this: include the purchase, but do not claim VAT that was never passed on by a VAT-registered supplier.

Practical Step-by-Step Guide for VAT-Registered Buyers

1. Confirm your own taxpayer status

The SLP requirement applies to VAT taxpayers. BIR Form 2550Q must be filed by VAT-registered persons and persons required to register as VAT taxpayers but who failed to register. The BIR form guidelines also state that the VAT return is filed as long as VAT registration has not been cancelled, even if there is no taxable transaction during the quarter. (Bir CDN)

If you are a non-VAT taxpayer, you normally do not file VAT returns or SLSP as a VAT taxpayer.

2. Check the supplier’s invoice and registration status

Look at the supplier’s invoice. In practice, the invoice may show clues such as:

“Non-VAT”
“VAT”
“VAT-registered TIN”
“NON-VAT TIN”
No VAT breakdown
No separate VAT amount

A VAT-registered supplier should issue a VAT invoice. A non-VAT supplier should not bill you VAT.

Under Republic Act No. 11976, all persons subject to internal revenue tax must issue registered sales or commercial invoices for sales or services valued at ₱500 or more, and must issue an invoice when the buyer requires it regardless of amount. VAT-registered persons must issue duly registered invoices regardless of the amount of the sale. (Lawphil)

3. Separate VAT and non-VAT purchases before encoding

Before preparing the SLP, classify purchases into buckets:

Purchase bucket	Example	Encoding reminder
VATable local purchases	Office equipment from VAT-registered supplier	Encode net of VAT and input VAT separately
Non-VAT supplier purchases	Services from non-VAT freelancer or small business	Encode as exempt/non-VAT; no input VAT
VAT-exempt goods/services	Certain agricultural products, exempt services, qualifying transactions	Encode as exempt; no input VAT
Zero-rated purchases	Qualified zero-rated local purchase	Encode as zero-rated
Imports	Imported goods with BOC documents	Use importation schedule

This step prevents the common error of putting everything under “purchases subject to VAT.”

4. Use the supplier’s exact BIR-registered details

The SLP requires the seller’s BIR-registered name, address, and TIN. (Bir CDN)

In real BIR audits, mismatches often happen because of small details:

Trade name encoded instead of registered name
Wrong branch code
Missing 00000 branch extension
Old address from an outdated invoice
Typographical errors in TIN
Individual supplier encoded under nickname rather than BIR name

If the supplier’s invoice is unclear, request a corrected invoice or confirmation of registered details.

5. Consolidate monthly purchases per supplier

The quarterly summary lists generally reflect consolidated monthly transactions per seller or supplier for each of the three months of the VAT quarter. (Bir CDN)

For example, if you bought from the same non-VAT supplier in January, February, and March, do not merely lump all amounts into one unsupported total. Your working file should be able to show the monthly breakdown.

6. Reconcile the SLP with the VAT return and books

Before submission, compare:

SLP totals
Purchase journal
General ledger
Expense accounts
Inventory accounts
Fixed asset schedule
BIR Form 2550Q purchases and input tax fields
Withholding tax records, if applicable
Supplier invoices and payment vouchers

The BIR can compare your declared purchases with suppliers’ declared sales and may also compare your SLP with your VAT return. Failure to submit proper summary lists can trigger BIR review or audit issues. Revenue Regulations No. 16-2005 provides that failure to submit the quarterly summary lists in the prescribed manner is punishable under the Tax Code and can trigger an audit of VAT liabilities. (Bir CDN)

7. Submit on time through the applicable BIR channel

BIR Form 2550Q is filed within 25 days following the close of each taxable quarter. The BIR’s form guidelines state that filing is generally electronic, with manual filing allowed if electronic platforms are unavailable, and payment may be made through available electronic platforms or manually through Authorized Agent Banks or Revenue Collection Officers. (Bir CDN)

For SLP/SLSPI, the applicable deadline and channel may differ depending on whether the taxpayer is non-eFPS, eFPS, or under the Large Taxpayers Service. In practice, non-eFPS taxpayers commonly submit with the quarterly VAT filing deadline, while eFPS or LTS taxpayers should check the current BIR tax calendar or RDO/LT office advisory.

Required Documents and Records to Keep

The SLP is only as strong as the records behind it. Keep the documents that prove the purchase actually happened, was business-related, and was correctly classified.

Document	Why it matters
Registered sales/commercial invoice from supplier	Main proof of purchase
Supplier TIN and registered name	Required for SLP encoding
Purchase order, contract, or service agreement	Shows business purpose and terms
Delivery receipt, receiving report, or acceptance document	Supports actual receipt of goods/services
Official payment proof	Check voucher, bank transfer, deposit slip, online payment record
General ledger and purchase journal	Reconciliation with books
VAT return, SLP file, and validation/submission proof	Shows tax compliance
BIR Form 2307, if withholding tax applies	Supports withholding tax treatment
BIR Form 1600, if VAT was withheld on non-resident services	Supports special VAT withholding treatment
Import entry, BOC documents, and VAT payment proof	Needed for importations

A non-VAT invoice is still important. It may not support input VAT, but it supports the purchase amount for accounting, income tax, withholding tax, and SLP reconciliation purposes.

Common Mistakes and How to Avoid Them

Mistake 1: Claiming input VAT from a non-VAT supplier

This is the biggest risk. If the supplier is non-VAT, there is no 12% VAT passed on to you as input tax. Do not back-compute VAT from the gross invoice amount.

Wrong:

Invoice amount: ₱112,000
Buyer records purchase as ₱100,000 plus ₱12,000 input VAT

Correct, if supplier is non-VAT:

Purchase amount: ₱112,000
Input VAT: ₱0

Mistake 2: Excluding all non-VAT purchases from the SLP

Some taxpayers think the SLP is only for input VAT. That is not correct. The BIR regulations expressly include exempt and zero-rated purchases in the purchase schedule. (Bir CDN)

If you exclude large non-VAT purchases, your SLP may not reconcile with your books and VAT return support schedules.

Mistake 3: Treating “exempt purchase” and “no document” as the same thing

A purchase from a non-VAT supplier may be exempt or non-VAT for VAT purposes, but it still needs a proper invoice. “Non-VAT” does not mean “no invoice needed.”

Mistake 4: Using the wrong supplier TIN

The BIR’s matching system relies heavily on TINs. A wrong TIN can make a valid purchase look suspicious.

Ask for an invoice showing the supplier’s correct TIN and branch code. Avoid relying only on screenshots, informal receipts, or payment confirmations.

Mistake 5: Confusing foreign suppliers with local non-VAT suppliers

A foreign supplier with no Philippine TIN is not the same as a local non-VAT supplier.

For services rendered in the Philippines by non-residents, older VAT regulations state that no summary list is required for the claimed input tax arising from such services, and VAT withheld and remitted through BIR Form No. 1600 may serve as substantiation under the rules. (Bir CDN)

For imported goods, use the Summary List of Importations and keep Bureau of Customs documents.

Mistake 6: Ignoring EOPT invoicing changes

The Ease of Paying Taxes Act harmonized the VAT treatment of goods and services and emphasized the invoice system. The BIR’s EOPT materials state that the VAT invoice is the supporting document for declaring output tax and claiming input tax, and that gross sales is now the unified basis for goods, services, and leases.

For 2026 transactions, businesses should be especially careful to obtain proper registered invoices rather than relying on old-style official receipts as the main purchase document.

Special Scenarios

Purchases from freelancers or professionals

If the freelancer is BIR-registered as non-VAT, the purchase may be included in the SLP as a non-VAT or exempt purchase. Do not claim input VAT.

Also check whether expanded withholding tax applies. Withholding tax compliance is separate from VAT reporting.

Purchases from sari-sari stores or small informal suppliers

If the purchase is for business, you should still require a valid invoice. In practice, this is difficult when dealing with very small vendors. For VAT and audit purposes, weak documentation creates problems even if the purchase is real.

If your business regularly buys from small suppliers, it is better to deal with BIR-registered suppliers that can issue proper invoices.

Purchases from a supplier that recently changed from non-VAT to VAT

Classify based on the supplier’s status and invoice at the time of the transaction.

If January invoices are non-VAT and March invoices are VAT invoices, do not apply one treatment to the whole quarter. Separate them by invoice date and classification.

Foreign-owned Philippine companies

A foreign-owned domestic corporation, Philippine branch, ROHQ/RHQ, or foreigner-owned sole proprietorship follows the same VAT and SLP rules if it is registered or required to register for VAT in the Philippines. The nationality of the owners does not change the SLP classification.

The practical issue is usually documentation: foreign headquarters invoices, intercompany charges, imported services, and foreign supplier contracts must be analyzed separately from local non-VAT supplier invoices.

Penalties and Audit Risk

Failure to file or correctly submit the quarterly summary list may result in penalties. Revenue Regulations No. 16-2005 states that a person who fails to file, keep, or supply a required statement, list, or information on time may be subject to an administrative penalty of ₱1,000 for each failure, with an aggregate cap of ₱25,000 during a taxable year, unless the failure is due to reasonable cause and not willful neglect. It also states that willful failure to keep records or supply correct and accurate information may lead to criminal penalties under the Tax Code. (Bir CDN)

Under the EOPT Act, micro and small taxpayers enjoy certain concessions, including reduced civil penalties and a reduced fine for failure to file certain information under Section 250 of the Tax Code.

In real audits, the bigger exposure is often not just the fixed penalty. The bigger problem is that incorrect SLP reporting can lead to:

disallowed input VAT;
VAT deficiency assessments;
mismatch letters;
expanded withholding tax issues;
questions on deductibility of expenses;
supplier confirmation checks;
longer audit proceedings.

Official References Worth Checking

Official source	Why it matters
Revenue Regulations No. 1-2012 on mandatory SLSP submission	Makes quarterly SLSP submission mandatory for VAT taxpayers
Revenue Regulations No. 16-2005 VAT Regulations	Contains the detailed SLP contents and classification rules
BIR Form No. 2550Q Guidelines	Explains who files the quarterly VAT return and when
Republic Act No. 11976, Ease of Paying Taxes Act	Updated invoicing, filing, payment, and taxpayer classification rules
BIR Ease of Paying Taxes page	Central BIR page for EOPT issuances and advisories

Frequently Asked Questions

Should I include non-VAT purchases in the Summary List of Purchases?

Yes, if you are a VAT taxpayer preparing the SLP and the purchases are part of your business purchases for the quarter. They should usually be classified as exempt or non-VAT purchases, not VATable purchases.

Can I claim input VAT from a non-VAT supplier?

No. A non-VAT supplier cannot pass on VAT. You should not compute 12% input VAT from a non-VAT invoice.

Where do I put non-VAT supplier purchases in the SLP?

In the exempt purchases or appropriate non-VAT/exempt field of the BIR module or your tax software. Do not put them under purchases subject to VAT.

Do I divide a non-VAT invoice by 1.12?

No. If the supplier is non-VAT, the invoice amount is not VAT-inclusive. Record the full invoice amount as the purchase amount, with zero input VAT.

What if the supplier writes “VAT included” but is actually non-VAT?

That is a red flag. Ask for a corrected invoice or proof of VAT registration. If the supplier is not VAT-registered, you should not claim input VAT even if the invoice language is confusing.

Does the non-VAT supplier need to file SLSP because I included them?

No. Your SLP filing does not automatically make the supplier a VAT taxpayer. The supplier’s own filing obligations depend on its BIR registration and tax classification.

Are purchases without invoices included in the SLP?

They should not be casually included without support. For BIR purposes, you need proper invoices and records. Unsupported purchases can create problems for VAT, income tax deductions, and audit reconciliation.

Are foreign supplier purchases included as non-VAT purchases?

Not necessarily. Foreign supplier transactions must be analyzed separately. Imported goods go to the importation schedule. Services from non-residents may involve VAT withholding and BIR Form 1600 rather than ordinary local SLP encoding.

What if I already encoded non-VAT purchases as VATable?

Review the filed data, VAT return, and input VAT claimed. If input VAT was wrongly claimed, correction may require an amended return, corrected SLP submission, and payment of any tax, surcharge, interest, or penalties due depending on the facts.

Is SLP filing still required if there were no purchases?

A VAT-registered taxpayer generally continues filing VAT returns while VAT registration remains active. For SLP/SLSPI, follow the BIR module, current tax calendar, and RDO/LT office procedure for zero or no-transaction quarters. Keep proof of filing or attempted filing.

Key Takeaways

Non-VAT supplier purchases may be included in the Summary List of Purchases.
They should usually be reported as exempt or non-VAT purchases, not purchases subject to VAT.
No input VAT can be claimed from a non-VAT supplier.
Do not divide a non-VAT invoice by 1.12.
Use the supplier’s correct BIR-registered name, TIN, and address.
Reconcile the SLP with your VAT return, books, invoices, and purchase schedules.
Keep invoices and proof of payment even when no VAT is claimed.
Foreign suppliers, importations, and non-resident services have separate VAT documentation rules.
Incorrect SLP reporting can trigger BIR mismatch issues, disallowance of input VAT, penalties, or audit.