SLSP Filing for New Businesses with No Transactions in the Philippines

This article explains when and how a newly registered business in the Philippines should handle the Summary Lists of Sales and Purchases (SLSP), especially in quarters with no transactions. It’s written for founders, accountants, and compliance officers navigating first-year tax obligations.

1) What the SLSP is—and why it exists

The Summary List of Sales (SLS) and Summary List of Purchases (SLP)—collectively, SLSP—are quarterly information listings required by the Bureau of Internal Revenue (BIR) primarily from VAT-registered taxpayers. They are submitted in electronic form and allow the BIR to reconcile a seller’s declared output VAT with a buyer’s input VAT using cross-matching (formerly under the RELIEF program).

Purpose:

Promote third-party verification of VAT declarations (audit trail).
Detect under-declarations of sales or over-claims of purchases/input VAT.
Improve VAT system integrity without examining every invoice.

2) Who is required to file SLSP

Generally required: VAT-registered taxpayers (corporations, partnerships, sole proprietors, professionals) that have VATable activities in the quarter.
Typically not required:
- Non-VAT/Percentage tax taxpayers (unless separately mandated by a BIR issuance).
- Individuals/entities with no VATable sales or purchases in the quarter (see Section 3 for “no transactions”).

Practical rule of thumb: If you’re not VAT-registered, SLSP is ordinarily not part of your core obligations. If you are VAT-registered, SLSP is normally required—but a nil quarter changes what you must submit (or not submit), discussed next.

3) New businesses with no transactions: Are you required to file?

A. Newly VAT-registered, no sales and no purchases for the quarter

Usual treatment: No SLSP submission is required for that quarter because there is nothing to list (no customers, no suppliers, no importations).
Good practice: Keep internal evidence of non-activity (e.g., zero-activity ledger, bank statements, first invoice/OR issuance date) in case the BIR inquires.

B. Newly VAT-registered, no sales but with purchases (e.g., you bought laptops or services while pre-operational)

You generally must file the SLP (purchases) because there are reportable transactions that could give rise to input VAT—even if your sales are zero.

C. Newly VAT-registered, sales occurred but no purchases

You must file the SLS (sales) because you had VATable sales, even if there were no purchases to report.

D. Newly registered as Non-VAT (Percentage Tax/Other)

SLSP is generally not applicable unless a specific BIR directive requires it for your case. Your focus will be on your applicable percentage tax return and other attachments (e.g., QAP if you are a withholding agent), not the SLSP.

Important: While the prevailing interpretation is no SLSP required for a truly zero-activity quarter, practices can vary on the ground. Some RDOs or e-systems may prompt filers to submit “nil” files or annotations. Maintain documentation and check your Certificate of Registration (BIR Form 2303) and any registration notes from your RDO.

4) Period covered and deadlines

Coverage: Quarterly (aligned with your VAT quarter).
Deadline: Within 25 days after the close of each quarter is the long-standing benchmark used in practice for SLSP submissions.
VAT return vs. SLSP: Your VAT return (BIR Form 2550Q) and your SLSP are distinct obligations. You can have no VAT due and still need to submit an SLS or SLP if you had any sales or purchases, respectively.

5) What goes into the SLSP (when there are transactions)

When applicable, the SLSP typically includes:

Taxpayer identification (yours) and period covered.
For SLS (sales): Customer TIN and name, gross sales per customer, VATable/zero-rated/exempt portions, output VAT.
For SLP (purchases): Supplier TIN and name, gross purchases per supplier, domestic purchases vs. importations, VATable/exempt split, and input VAT.

Level of detail: Report by customer/supplier for the quarter, aggregated totals per counterparty. Keep your official receipts/sales invoices and supplier invoices as source documents.

6) Pre-operational and first-year scenarios (examples)

Quarter 1: You registered for VAT in January; no invoices issued; no purchases booked.
- Result: No SLSP to file for Q1. Keep proof of non-activity.
Quarter 1: You registered for VAT in January; you bought inventory in March; no sales yet.
- Result: File SLP only for Q1 (report purchases). No SLS.
Quarter 1: You issued your first sales invoice in March; you had no purchases.
- Result: File SLS only for Q1 (report sales). No SLP.
Quarter 1: You are non-VAT; you made small cash sales under percentage tax and minor purchases.
- Result: SLSP generally not required. Focus on your percentage tax return and other applicable reports.

7) How SLSP is submitted (mechanics overview)

Electronic submission: SLSP is transmitted in soft copy using the prescribed electronic format.
Validation/acknowledgment: The BIR system issues an acknowledgment (e.g., validation or email confimation) when the file is accepted. Keep it with your quarter’s compliance file.
Record retention: Keep source documents and electronic working files for the statutory retention period (usually 10 years in practice: 3 years generally prescriptive for assessment plus extended retention recommended for audit trail; some businesses keep 10 years to be safe).

Tip: Align your SLSP working schedules with your VAT returns and books of accounts to ensure consistency.

8) Penalties and risks

Failure to file when required (e.g., you had purchases or sales but did not submit the relevant SLP or SLS) may trigger:
- Compromise penalties for failure to file an information return.
- Administrative fines and possible LOA/Audit selection.
- Mismatch findings (e.g., your supplier reported a sale to you in their SLS but you did not report the corresponding purchase in your SLP, or vice versa).
No-activity quarters: There is no penalty for not submitting SLSP where no SLSP was required (i.e., truly no reportable transactions). Your defense is your books and records showing no activity.

9) Documentation to keep for a zero-activity quarter

If you are skipping SLSP because you had no transactions, keep:

Books of accounts (general ledger/journal) showing no entries.
Bank statements showing no business flows (or minimal capitalization only).
Supplier/customer onboarding files (if any) showing no invoices were exchanged.
Board/owner notes on the commencement date of actual operations.
Copy of BIR Form 2303 and any written guidance from the RDO at registration.

10) Internal controls for first-time filers

Cut-off controls: Define when an invoice “belongs” to a quarter (invoice date rules your SLSP period).
Masterfile hygiene: Maintain accurate TINs and legal names for customers/suppliers to avoid validation errors.
Reconciliation steps:
1. Tie SLS totals to VAT return output VAT base.
2. Tie SLP totals to input VAT claimed (and to accounts payable).
3. Investigate anomalies (e.g., a supplier reported you but you didn’t record a purchase).

11) Frequently asked questions

Q1: I’m VAT-registered but had no sales and no purchases this quarter. Should I submit a “nil” SLSP? A: As a rule, no—because there is nothing to list. However, some taxpayers opt to keep a “nil” working file and confirm with their RDO if their e-profile shows SLSP due. Maintain strong zero-activity documentation.

Q2: I bought equipment in my first quarter but had no sales. A: File SLP for that quarter. If you intend to claim input VAT, ensure the invoice is VAT-compliant and the supplier is VAT-registered.

Q3: I’m non-VAT. Does SLSP apply to me? A: Generally no. SLSP is primarily a VAT listing requirement.

Q4: I missed filing SLP for a quarter with purchases but no sales. A: File as soon as possible and prepare for possible penalties and inquiries. Ensure your VAT return and books reconcile.

Q5: Do I need to include importations in SLP? A: Yes. Importations are part of reportable purchases and should be tagged accordingly.

12) Action checklist for a brand-new business

Confirm your tax type (VAT or Non-VAT) on BIR Form 2303.
Calendar your VAT quarters and the SLSP 25-day post-quarter deadline.
For zero-activity quarters (VAT): Document non-activity; no SLSP filing is typically needed.
For quarters with activity:
- Sales only → SLS required.
- Purchases only (including imports) → SLP required.
- Both → SLS and SLP required.
Archive the system acknowledgment, working files, and reconciliations with your VAT return.
Monitor RDO/e-system notices; update processes if your RDO requires a specific local practice (e.g., nil annotations).

13) Key takeaways

SLSP is a quarterly information listing aimed at VAT cross-matching.
New VAT businesses with no transactions in a quarter generally do not need to file SLSP for that quarter.
The moment you have sales or purchases/imports, the relevant SLS or SLP becomes due.
Keep tight records and reconcile to your VAT return to avoid mismatches and audit exposure.

This article is for general informational purposes and does not constitute legal or tax advice. For case-specific guidance, consult your tax adviser or your RDO.