BIR Form 2307 for Ambulance and Medical Transport Service Providers

A hospital, HMO, or company that pays a private ambulance or medical transport provider for patient transport withholds 2% expanded withholding tax (EWT) on the dispatch fee, the same general contractor/business-services rate this series already applies to couriers and towing companies — not the goods-only “transportation contractor” clause in Revenue Regulations (RR) No. 2-98, which names cargo, not patients.

This guide is part of the BIR Form 2307 series. It covers why a passenger/patient carrier sits outside the goods-carriage clause, the rate and ATC code that apply instead, who is the withholding agent when an HMO, a hospital, and a patient’s employer are all part of the same reimbursement chain, and a worked per-dispatch example.

Is an ambulance or medical transport company’s fee subject to withholding tax? #

Yes — a private ambulance or medical transport company is a service provider paid for hire, and any corporate or business-registered individual payor that pays it must withhold EWT before releasing payment. RR No. 2-98 sets the withholding-agent test this way:

“(A) In general, any juridical person, whether or not engaged in trade or business; (B) An individual, with respect to payments made in connection with his trade or business…”

— RR No. 2-98, Section 2.57.3(A)–(B)

A hospital contracting a standing ambulance provider for inter-facility patient transfers, an HMO dispatching an accredited ambulance company to a member’s home, or a corporate client with its own company clinic engaging a medical transport service for employee emergencies are all withholding agents under clauses (A) or (B). This is distinct from the rule covered in BIR Form 2307 for Medical Practitioners, which addresses a doctor’s own professional fee, not a third-party transport vendor’s dispatch charge.

Why the goods-only “transportation contractor” clause doesn’t apply #

RR No. 2-98’s transportation-contractor sub-item is written around cargo, not people, so an ambulance or medical transport company does not fall under it even though both are “transport” businesses in everyday language. The regulation names the covered activity specifically:

“Transportation contractors which include common carriers for the carriage of goods and merchandise of whatever kind by land, air or water, where the gross payments by the payor to the same payee amounts to at least two thousand pesos (₱2,000) per month, regardless of the number of shipments during the month.”

— Section 2.57.2(E) of Revenue Regulations No. 2-98

As BIR Form 2307 for Trucking and Cargo Hauling Companies explains, this clause and its ₱2,000-a-month floor exist for haulers moving goods and merchandise — a steel distributor’s trucking contract, a manufacturer’s inter-branch freight run. An ambulance carries a patient on a stretcher, not merchandise in a hold, so the clause’s own wording does not reach it. That does not mean ambulance services escape withholding altogether — it means they fall into the broader catch-all described next, the same bracket this series already applies to couriers and to towing and vehicle recovery services, which likewise move something (a package, a disabled car) without qualifying as a “common carrier of goods.”

What rate and ATC code apply to an ambulance or medical transport company? #

An ambulance or private medical transport company’s dispatch fee falls under the flat 2% general contractor/business-services bracket of RR No. 2-98 Section 2.57.2(E), as amended by RR No. 11-2018 — the same catch-all covered in BIR Form 2307 for Contractors and Subcontractors. No special lower or exempt rate applies to ambulance or patient-transport services specifically; absent a named carve-out, a contracted service provider defaults to this bracket.

Because the monetary floor quoted above belongs specifically to the goods-carriage sub-item, the general contractor/business-services bracket that ambulance services actually fall under carries no equivalent monthly minimum in the regulation’s text — withholding applies to the dispatch fee from the first payment, not only once a running total crosses a threshold.

Who withholds when billing runs through an HMO reimbursement chain? #

The withholding agent is whichever entity actually pays the ambulance company directly — not whichever entity ultimately bears the cost once reimbursement is sorted out. A patient transport bill routed through an HMO can settle in several different ways, and the party at the point of payment changes depending on how the contract is structured:

1. Hospital pays, then bills the HMO. A hospital contracts and pays the ambulance company for an inter-facility transfer, folding the charge into the patient’s total bill, and separately invoices the HMO for reimbursement under the member’s plan. The hospital is the withholding agent — it is the one paying the ambulance company — regardless of what the HMO reimburses afterward.
2. HMO pays its accredited provider directly. Some HMOs maintain their own panel of accredited ambulance or medical transport providers and dispatch and pay them directly for a member’s emergency transport, later itemizing the cost against the employer’s group policy. Here the HMO is the withholding agent, because it is the HMO’s payment that reaches the ambulance company.
3. Employee pays, employer reimburses. If a patient or family member pays the ambulance company out of pocket and the patient’s employer later reimburses that expense, neither the employee nor the employer withholds on that specific payment: the employee is an individual not acting in trade or business when arranging personal emergency transport, and the employer never pays the ambulance company directly — it is reimbursing its employee, not paying the payee. See What Is BIR Form 2307 for the general payor-withholds principle this follows.

In every scenario, the certificate obligation tracks the actual payment, not the ultimate funding source — the same logic the hospital-withholding rule for doctors’ professional fees applies when a hospital’s billing system, rather than the patient, is what the ambulance company (or the doctor) is actually paid through.

Worked example: a standing HMO-ambulance dispatch agreement #

MetroCare HMO, Inc. maintains a standing service agreement with RapidCare Ambulance Services, Inc., an accredited private ambulance operator, to dispatch patient transport for MetroCare members at a flat ₱8,000 per dispatch. Because MetroCare pays RapidCare directly under this panel agreement (scenario 2 above), MetroCare is the withholding agent. RapidCare is organized as a corporation, so ATC WC120 at 2% applies:

If MetroCare uses RapidCare for 10 dispatches in a month, the cumulative gross fee is ₱80,000 and the cumulative EWT is ₱1,600 — MetroCare remits this through BIR Form 0619-E monthly and BIR Form 1601-EQ quarterly, lists RapidCare on its Quarterly Alphalist of Payees, and issues a BIR Form 2307 showing the total income payment, ATC WC120, and total tax withheld for the period. RapidCare credits that ₱1,600 against its own income tax due.

Contrast with scenario 1: had a hospital instead contracted and paid RapidCare directly for the same ₱8,000 dispatch — folding the charge into the patient’s bill and separately invoicing MetroCare for reimbursement — the hospital, not MetroCare, would be the one withholding the ₱160 and issuing the certificate. The rate and ATC are identical either way; only the name on the certificate’s withholding-agent field changes with who actually paid.

Summary #

A private ambulance or medical transport company’s dispatch fee is withheld at a flat 2% under RR No. 2-98 Section 2.57.2(E)’s general contractor/business-services bracket (ATC WI120/WC120) — not the goods-only transportation-contractor clause, which by its own wording covers carriage of merchandise, not patients, and carries a ₱2,000-a-month floor this broader bracket does not share. When billing runs through an HMO reimbursement chain, the withholding agent is whichever party — hospital, HMO, or (rarely) a direct corporate client — actually pays the ambulance company, not whichever party ultimately absorbs the cost. For the related rule on a hospital’s own withholding duty toward attending doctors, see BIR Form 2307 for Medical Practitioners, and for how the goods-carriage sub-item this post distinguishes from actually works, see BIR Form 2307 for Trucking and Cargo Hauling Companies.

Frequently asked questions #

Does a hospital, HMO, or company have to withhold tax when paying a private ambulance or medical transport company? #

Yes, if the payor is a corporation or an individual paying in connection with a trade or business. A hospital, HMO, or company that pays a private ambulance or medical transport provider for patient transport is a withholding agent under RR No. 2-98, Section 2.57.3(A)-(B), and withholds 2% expanded withholding tax on the dispatch fee, then issues BIR Form 2307.

What withholding tax rate applies to an ambulance or medical transport company’s fee? #

An ambulance or private medical transport company’s dispatch fee is not named as its own line item in RR No. 2-98, so it falls under the flat 2% general contractor/business-services bracket under Section 2.57.2(E), as amended by RR No. 11-2018 — ATC WI120 for an individually run service, WC120 for one organized as a corporation.

Why doesn’t the ₱2,000-a-month transportation-contractor threshold apply to ambulance services? #

The ₱2,000-a-month floor in Section 2.57.2(E) is written specifically into the sub-item for common carriers hauling goods and merchandise — it names cargo, not passengers. An ambulance or medical transport company carries patients, not goods, so it is withheld under the broader general contractor/business-services catch-all instead, which carries no equivalent monthly floor in the regulation’s text — withholding applies from the first peso paid.

When an HMO reimburses a hospital’s ambulance cost, who is the withholding agent — the HMO or the hospital? #

Whichever entity actually pays the ambulance company directly is the withholding agent, regardless of who ultimately absorbs the cost. If the hospital contracts and pays the ambulance company and later bills the HMO for reimbursement, the hospital withholds. If the HMO instead dispatches and pays its accredited ambulance provider directly under its own panel agreement, the HMO withholds — the reimbursement flow behind the payment does not change who withheld at the point of payment.

Does a patient’s employer withhold tax if it simply reimburses an employee for an ambulance ride? #

Generally no. If the employee personally pays the ambulance company and the employer later reimburses that employee as an expense reimbursement, the employer never pays the ambulance company directly, so it has no withholding obligation on that payment. The employee, as an individual not acting in the course of trade or business when arranging emergency transport for themselves or a dependent, also has no withholding duty under Section 2.57.3(B).