Is a Treasurer’s Signature Required on BIR Form 2307? Compliance Guide

Quick answer

A Treasurer’s signature is not strictly required on BIR Form 2307 (Certificate of Creditable Tax Withheld at Source). What’s required is that the form be duly accomplished and signed by the withholding agent (payor) or its authorized representative. In many companies, the Treasurer signs because they are commonly designated as an authorized signatory—but the law and the form generally allow any properly authorized officer/representative to sign.

That said, the “right” signatory in practice depends on your entity type, internal delegations, and what the BIR (or an auditor) will accept as proof that the signer is authorized.


1) What BIR Form 2307 is (and why it matters)

BIR Form 2307 is the certificate issued by a withholding agent (the payor) to an income recipient (the payee) showing creditable withholding tax (CWT) that was withheld from payments subject to expanded/creditable withholding tax.

Why it’s important

  • For the payee: the amount in Form 2307 is typically claimed as a tax credit against income tax due (quarterly and/or annual).
  • For the payor/withholding agent: issuing Form 2307 is part of compliance, and it supports that the payor withheld and reported taxes properly.

Key point: For many transactions, a payee’s ability to claim the CWT as a credit hinges on having a properly executed Form 2307.


2) Legal framework (Philippine context)

Form 2307 sits under the broader system of:

  • Withholding tax obligations (payor withholds tax on certain income payments),
  • Remittance and reporting (payor remits the tax and files withholding returns), and
  • Issuance of withholding certificates (payor issues certificates to income recipients).

In general terms, Philippine tax rules require withholding agents to:

  1. Withhold the correct amount,
  2. Remit it to the BIR,
  3. Report it in the proper withholding tax returns, and
  4. Issue the corresponding certificate (Form 2307 for CWT).

3) What the form itself requires: “authorized representative,” not “treasurer”

Form 2307 typically contains a signature area along the lines of:

Signature over printed name of the payor/withholding agent / authorized representative (often with designation/title and date)

The operative requirement is a signature by the payor or an authorized representative—not a specific corporate officer title.

So why do people think “treasurer must sign”?

Because:

  • In many corporations, the Treasurer is the officer typically responsible for financial certifications and tax documents; and/or
  • Companies standardize signatories to control risk and consistency; and/or
  • During audits, officers like the Treasurer/CFO are perceived as “safer” signatories.

But these are practice preferences, not a universal legal mandate.


4) Who may sign Form 2307?

A) Corporations (domestic or resident foreign corporations)

Usually acceptable signatories include:

  • Treasurer
  • Chief Financial Officer / Finance Head
  • Accounting Head / Comptroller
  • Authorized signatory designated under a Board Resolution / Secretary’s Certificate
  • A duly appointed representative under a written authority (with internal documentation)

Best practice: If the signer is not the Treasurer, keep a Secretary’s Certificate/Board Resolution (or equivalent corporate authority) showing the person is authorized to sign tax certificates and related filings.

B) Sole proprietorships

  • The owner/taxpayer commonly signs, or
  • A duly authorized representative (with authority letter / SPA where appropriate)

C) Partnerships

  • A managing partner, partner, or
  • Authorized representative per partnership authority documents

D) Government payors

  • The authorized accountable officer or official designated to sign tax withholding certificates

5) “Required” vs “accepted”: the practical audit reality

Even if the rules don’t mandate “Treasurer only,” in real-world BIR interactions the question becomes:

Will the BIR accept it as valid support?

Most of the time, acceptance turns on whether the certificate is:

  • Complete (no missing key fields),
  • Consistent with withholding tax returns and remittances, and
  • Signed by someone who can reasonably be treated as authorized.

Higher scrutiny scenarios (where signatory authority matters more):

  • Tax refund / tax credit certificate claims
  • Large audits where the examiner checks documentary support closely
  • Situations with inconsistent names, TINs, or amounts

If you’re in one of these scenarios, using a clearly authorized corporate officer (often Treasurer/CFO) and maintaining authority documents reduces friction.


6) Is a “wet signature” required? What about scanned/digital signatures?

In many Philippine business settings, Form 2307 is issued:

  • With an original “wet” signature, or
  • With a scanned signature printed on the certificate, especially where certificates are system-generated

Practical compliance approach:

  • If the payee will use Form 2307 only for routine crediting in ITR filings, scanned signatures are commonly used in practice.
  • For high-stakes uses (refunds, large audits, disputed credits), it’s safer to secure original signed copies (or at least ensure you can substantiate authenticity and authority).

Because signature acceptability can become a fact-and-evidence issue, align with the risk level of the transaction.


7) Common compliance mistakes (and how to avoid them)

Mistake 1: Unsigned Form 2307

  • Impact: Payee may be disallowed from claiming the credit; BIR may treat it as defective support.
  • Fix: Ensure every issued certificate is signed by the authorized signatory.

Mistake 2: Wrong or inconsistent TIN/name

  • Impact: Matching problems during validation; credit denial risk.
  • Fix: Validate payee name/TIN against registration documents; standardize master data.

Mistake 3: Incorrect nature of income / ATC / tax rate

  • Impact: Withholding tax mismatches and potential deficiency assessments.
  • Fix: Map transaction types to correct ATCs and rates; implement review controls.

Mistake 4: Amounts don’t tie to returns/remittances

  • Impact: Payee credit may be questioned; payor may face audit issues.
  • Fix: Reconcile Form 2307 totals per quarter against withholding tax returns and schedules.

Mistake 5: Signing authority unclear

  • Impact: Payee/auditor may question validity; internal control weakness.
  • Fix: Maintain a signatory matrix + Secretary’s Certificate/authority letters.

8) Deadlines and timing: when to issue Form 2307

As a compliance principle, the withholding agent should issue Form 2307 to the income recipient timely, typically aligned with the quarter in which withholding occurred. Many organizations issue:

  • Per transaction, or
  • Monthly, or
  • Per quarter (consolidated)

Best practice: Agree on a consistent issuance schedule (e.g., within a set number of days after month/quarter-end) and document it in vendor/customer onboarding or contract terms.

(Exact timing rules can vary by issuance and practice; if you’re implementing policy, verify the latest BIR guidance relevant to your withholding type and filing method.)


9) Penalties and exposure (why proper signing matters)

For the payor/withholding agent

Noncompliance may lead to:

  • Exposure for deficiency withholding taxes (if underwithheld),
  • Surcharges, interest, and compromise penalties, and
  • Administrative issues for failure to comply with certificate issuance/documentary requirements

For the payee/income recipient

  • The creditable withholding tax may be disallowed as a tax credit if Form 2307 is defective, missing, or cannot be validated.

Because the payee’s credit is often a material cash/tax position, an unsigned or improperly executed 2307 can create real commercial disputes.


10) Practical checklist: “Is our Form 2307 audit-ready?”

Required fields (high priority)

  • Correct payor name/TIN/address
  • Correct payee name/TIN/address
  • Correct period/quarter
  • Correct nature of income / ATC
  • Correct tax base and withheld amount
  • Signature over printed name + designation/title + date

Supporting documents to keep (especially for payors)

  • Proof of withholding and remittance (returns, schedules, payment confirmations)
  • Authority documents for the signatory (Secretary’s Certificate/Board Resolution or internal delegation policy)
  • Reconciliation of issued 2307 vs filed returns per quarter

11) FAQs

“We don’t have a Treasurer. Can our Accounting Manager sign?”

Yes—if the Accounting Manager is an authorized representative. Document the authority (company policy, delegation memo, or Secretary’s Certificate for corporations).

“Our client demands the Treasurer’s signature specifically. Are they right?”

They’re not necessarily stating a legal requirement; they may be imposing a commercial control requirement. If you want to accommodate, you can; otherwise, provide proof that the signatory is authorized.

“Can we issue a consolidated 2307 per quarter instead of per invoice?”

Often yes in practice, as long as it accurately reflects withheld amounts for the period and matches your returns/schedules. Ensure your internal reconciliation is strong and the payee agrees operationally.

“If the form is unsigned, can the payee still claim the credit?”

That’s risky. In many examinations, an unsigned certificate is treated as defective substantiation. The safer approach is to re-issue a properly signed Form 2307.


Bottom line

  • No, a Treasurer’s signature is not inherently required on BIR Form 2307.
  • What’s required is a signature by the withholding agent or a duly authorized representative.
  • For smoother audits and fewer disputes, use a clearly authorized signatory (Treasurer/CFO/authorized officer) and keep authority documentation ready—especially for high-risk uses like refund/credit claims.

If you want, share your entity type (corporation/sole prop/partnership/government) and how you currently issue 2307 (per transaction/monthly/quarterly), and I’ll map out a tight signatory and controls policy you can implement internally.

Disclaimer: This content is not legal advice and may involve AI assistance. Information may be inaccurate.