RMC No. 48-2024 prescribed the policies and procedures in the proper manner of accomplishing the new version of the Monthly Documentary Stamp Tax Declaration/Return (BIR Form No. 2000 ver. 2018), some issues were raised by the taxpayers-users who are using electronic Documentary Stamp tax System (eDST System) as well as those who are filing using the said form through electronic Filing and Payment System (eFPS).
This Circular was issued to clarify and address the following issues and concerns:
- Issue: Additional requirement of filing BIR Form No. 2000 for total DST due declaration from all taxable documents that were made, signed, accepted or transferred during the month considering that these taxable transactions are already encoded in the taxpayers’ ledger of the eDST System as utilizations from their advance deposits.
Clarification: In general, a tax return is an official form containing the prescribed details in computing the tax due that the taxpayers should pay to the taxing authority. BIR Form No. 2000, when used for advance deposit remittances by the users of eDST System, is not yet a return, but as a form of payment. Due to certain limitations of the current format of BIR Form No. 2000 version 2018, the same form shall still be used separately in declaring the taxable transactions for total DST due computation of these taxpayers, pending the revision of the said form.
- Issue: Due to large volume of transactions of certain taxpayers, the encoding process of these transactions in schedule 1 (Summary of Computation of taxes Due for the Month) of the said form suddenly suspends (i.e., continuously buffer or “hang”) after an initial number of encoded transactions which compels taxpayers to terminate the encoding process. However, upon resumption, the previously encoded transactions were already lost.
Revised Procedures: Considering that the taxable transactions of the taxpayers are already captured by the eDST System when the corresponding tax dues are utilized as deductions from advance deposit and for purposes of addressing the technical limitations of the eFPS in accomplishing Schedule 1 of the form involving large volume of transactions, the encoding of Alphanumeric Tax Code (ATC) No. 010 and the amount under the “Tax Due” column equivalent to the total tax due for the month reflected in the taxpayer’s ledger of said system must be sufficient in accomplishing the said schedule.
- Issue: Inability to generate the form or delay in filing the declaration by several attempts to finally accomplishing the schedule 1 and generate the form considering that only five (5) days (i.e., prescribed number of days after the close of the month) within which to file the form. Consequently, the eFPS automatically computes the penalties due to late filing of the form within the prescribed deadline, which should not be attributed to the taxpayer.
Clarification: The filing of BIR Form No. 2000, when used as declaration for taxable transactions in computing the DST due. eDSt taxpayer-user cannot be held liable for penalties computed in the eFPS because the DST dues were already paid in advance in the form of deposits and utilizations which can be validated from eDST system. Considering that the eFPS has no facility to distinguish whether the said form is being filed as a tax return or as a declaration, the corresponding amount for compromise penalty for late filing of the said form as a declaration shall be the penalty of the eDST user.
- Issue: The total penalty computed by the eFPS is based on the total tax due which is a very significant amount on the part of the taxpayers as it is not a proportion to the violation of filing of a simple declaration within the prescribed deadline.
Clarification: In consideration with the technical limitation of the eFPS in accomplishing Schedule 1 of the said form involving large volume transactions, the compromise penalties which are otherwise due resulting from non-filing or late filing by eDST taxpayers-users of the said form as declaration covering the previous taxable months from the date of issuance of RMC No. 48-2024 will no longer be assessed and collected.