Digesting BIR RR-21-2020 - VAPP

by: Mark Virgil Lofranco, CPA

Voluntary Assessment and Payment Program for Taxable year 2018 under Certain Conditions


Covered Taxes and Taxable Year; when to avail


When to avail?


Covered Person



Not covered


How to apply?

Mandatory Requirements?



Additional Requirements


Manner of Payment



All voluntary payments should be made in cash.

Tax debit memo is not a valid payment




The duly accomplished form no. 0622 shall be presented for payment to any BIR authorized agent bank or authorized collecting agent under registered RDO.

If ONETT involving sale of property, it must be filed and paid under the RDO where the property is located


Proceeding during review


Within 30 days


the Revenue Officer will evaluate the application, payment form and other documents submitted

endorse them to the assistant chief,  LT office/Assistant District Officer for review

endorse to the chief, LT office/revenue district officer, as the case may be, for approval

BIR form 2119 shall be signed by  the chief, LT office/revenue district officer


If the review reveals deficiencies or defects, the approving official shall notify the applicant through email address provided and shall require to rectify the defects and/or comply with or pay the deficiencies within 10 working days from receipt of the notification/email.


Failure to act and/or pay the required amount within the period shall result to the denial of the application.


A certificate of availment shall be issued within 3 working days from approval of the application as a proof of the availment, compliance with the requirements and entitlement to the privilege.


The LT office or RDO shall transmit all dockets on approved VAPP applications to the concerned reviewing office not later than the 5th day following the month of issuance of the Certificate of availment for post review.







Consequence of non-submission; erroneous submission, incomplete/falsified submission; treatment of invalid/deficient or defective availment


Shall not entitle to avail of the privilege thus voluntary payment may be applied against any deficiency tax liability for the taxable year 2018 in case of audit/investigation


Taxpayer’s failure to file and pay tax returns for the covered taxable year; condition to avail


If the unfiled tax returns shall first be filed and/or

If the unpaid taxes plus corresponding penalties for late filing and payment shall first be paid


Condition to avail the privilege; amounts to be paid


The amount of taxes to be paid as a condition to avail the privilege:


Income Tax, VAT, Percentage Tax, Excise Tax and Documentary Stamp Tax other than DST on ONETT


Increase/Decrease in total taxes due from 2017 and 2018
Amount of voluntary tax payment (whichever is higher)
 Net increase of not more than 10%
3% of 2018 gross sales OR 7% 2018 taxable net income
Net Increase of more than 10% up to 30%
2% of 2018 gross sales OR 6% of 2018 taxable net income
Net increase of more than 30%
1% of 2018 gross sales OR 5% OF 2018 taxable net income



Minimum amount
For individuals, estates and trusts
For corporations
Subscribed capital of more than P50 Million
For corporations
Subscribed capital of more than P20 Million-P50 Million
For corporations
Subscribed capital of more than P5 Million-P20 Million
For corporations
Subscribed capital of P5 Million and less
Other juridical entities including but not limited to cooperatives, general professional partnerships


Final withholding taxes (Compensation, fringe benefits, etc.), Creditable withholding taxes other than CWT on ONETT


Amount shall be 5% of the total basic withholding tax remittance for the taxable year 2018


For taxpayers with claims for tax refund/credit, the application shall constitute a waiver of such claims unless they exclude in their availment the specific type for which they are pursuing the claim for tax credit/refund.


Taxes on ONETT such as Estate tax, donor’s tax, Capital gains tax, ONETT-related CWT/Expanded withholding tax and DST


Amount paid shall be the basic tax due of the unfiled tax return/unpaid tax due plus 5%.


Benefits and Privilege


Shall not be audited for 2018 for the tax types covered by the availment

If the covered taxable period are currently being audited, the conduct of the audit shall be suspended upon the availment of the VAPP while the availment is under evaluation. It shall resume of the availment has been found invalid.

If the availment has been determined to be valid, a certificate of availment shall be issued and the Letter of Authority, Tax verification notice, discrepancy notice, notice of informal conference, preliminary assessment notice, final assessment notice for pending cases shall be withdrawn and canceled.


Instances where audit and investigation are still allowed despite the issuance of certificate of availment:


There is strong evidence or finding of under-declaration of sales, receipts or income or overstatement of deductions by more than 30% based on written report of the appropriate revenue official stating the facts with supporting documents

There is verifiable information that the taxpayer has withheld but failed to remit withholding taxes


Non-availability of cash refund or credit; non-admission of fraud or erroneous payment


Any payment made is construed as a waiver for the right to claim for refund or credit notwithstanding collection from erroneous payment.


The act of voluntary payment shall not be deemed as an admission on the part of the taxpayer that there was fraud in the declaration of its taxes and/or there was an intention to pay the tax erroneously.