BIR Form 2307 for Real Estate and Insurance Appraisers

A bank, developer, or insurer that pays an individually licensed real estate appraiser for an appraisal report must withhold expanded withholding tax (EWT) and issue BIR Form 2307, because a real estate appraiser is both a licensed real estate service practitioner under Republic Act No. 9646 (the Real Estate Service Act, RESA) and a “professional appraiser” named directly in the enumeration under Section 2.57.2(A)(1) of RR No. 2-98. The rate and ATC code depend on whether the payee is the individual appraiser (5%/10%) or an appraisal firm organized as a corporation (10%/15%).

This guide is part of the BIR Form 2307 series. It builds on BIR Form 2307 for Real Estate Brokers and Real Estate Service Practitioners and BIR Form 2307 for Architects and Engineers, covering why a real estate appraiser is doubly grounded in the named-professional withholding bracket, the individual-vs-corporate rate split, the ATC codes, and a worked mortgage-appraisal example.

Is a real estate appraiser a named professional for withholding tax purposes? #

Yes, on two independent grounds. A real estate appraiser is a RA 9646-licensed real estate service practitioner (RESP) — the same licensing law that covers real estate brokers and consultants — and is also individually named as a “professional appraiser” in RR No. 2-98’s own enumeration of covered professions. BIR Form 2307 for Real Estate Brokers and Real Estate Service Practitioners already establishes that “real estate brokers, appraisers, and consultants — collectively ‘real estate service practitioners’ under Republic Act No. 9646 — are expressly listed among the professionals subject to expanded withholding tax under RR No. 11-2018,” so a RESA-licensed appraiser falls under the same RA 9646 umbrella as a licensed broker.

Separately, this site’s guides to marine and cargo surveyors and actuaries have already quoted the operative text of Section 2.57.2(A)(1) of RR No. 2-98, which lists covered individually engaged professionals by name:

“…architects; civil, electrical, chemical, mechanical, structural, industrial, mining, sanitary, metallurgical and geodetic engineers; marine surveyors; doctors of veterinary science; dentist; professional appraisers; connoisseurs of tobacco; actuaries; and interior decorators.”

— Section 2.57.2(A)(1) of Revenue Regulations No. 2-98, listing individually engaged professionals subject to expanded withholding tax

“Professional appraisers” sits in that same clause, alongside architects, engineers, and marine surveyors. A real estate appraiser valuing property therefore clears the named-professional test twice over — once through RA 9646 licensure as a real estate service practitioner, and once through RR No. 2-98’s own direct enumeration — which is a stronger basis than either ground alone.

Individual appraiser or appraisal corporation — why the payee type changes the rate #

The withholding rate and ATC code turn on who the actual payee is: an individually licensed real estate appraiser is withheld under the individual professional-fee rate, while an appraisal firm organized as a corporation is withheld under the corporate professional-fee rate — even though both are billing for the same kind of valuation work. This is the same individual-vs-entity distinction this series applies to real estate brokers, architects, and engineers.

A bank that engages “Benilde Property Appraisal Services” directly — billed under the individual appraiser’s own name and TIN — withholds using WI010/WI011. The same bank paying an invoice from “ValuExpert Appraisal Corp.” for identical valuation work withholds using WC010/WC011 instead, because the payee on that invoice is a corporation.

Who has to withhold on an appraiser’s fee? #

Any business or individual engaged in business — a bank, a real estate developer, an insurer, or a corporation — that pays a real estate appraiser for services in the course of that business is a withholding agent and must withhold EWT before releasing payment. Common payors include:

• A bank or lending institution engaging an appraiser to value a mortgaged or collateral property
• A real estate developer retaining an appraiser to establish fair market value before a sale
• A corporation commissioning an appraisal for financial reporting or asset revaluation purposes
• An estate or trust engaging an appraiser to value real property for settlement purposes

An individual homeowner privately commissioning a one-off appraisal outside any trade or business is generally not a withholding agent, consistent with the trade-or-business test this series applies throughout — withholding under RR No. 11-2018 attaches to a payor that is itself in business or in the practice of a profession, not to an ordinary personal transaction.

Worked example: a bank’s mortgage appraisal, individual vs. corporate appraiser #

A lending bank engages Benilde Property Appraisal Services, an individually licensed real estate appraiser, for ₱25,000 to appraise a property offered as mortgage collateral. Benilde bills the bank directly under the appraiser’s own name and TIN and has an Income Payee’s Sworn Declaration of Gross Receipts/Sales (Annex B-1) on file confirming gross income for the year has not exceeded ₱3,000,000, so ATC WI010 at 5% applies.

The bank remits the ₱1,250 withheld through BIR Form 0619-E monthly and BIR Form 1601-EQ quarterly, and issues Benilde Property Appraisal Services a BIR Form 2307 each quarter showing the cumulative professional fees paid, ATC WI010, and the total tax withheld, which the appraiser then credits against income tax due when filing BIR Form 1701Q/1701.

Had the bank instead engaged “ValuExpert Appraisal Corp.,” a corporation, for the identical mortgage appraisal, it would withhold using ATC WC010 at 10% (assuming the firm’s gross income for the year does not exceed ₱720,000) — ₱2,500 withheld on the same ₱25,000 fee, under a corporate ATC rather than the individual one, with no sworn-declaration requirement involved.

Frequently asked questions #

Is a real estate appraiser’s fee subject to expanded withholding tax? #

Yes. A real estate appraiser is a licensed real estate service practitioner under Republic Act No. 9646, the Real Estate Service Act (RESA), and Section 2.57.2(A)(1) of Revenue Regulations No. 2-98 separately names “professional appraisers” directly in its enumeration of individuals subject to expanded withholding tax. A bank, developer, or insurer that pays an individually licensed appraiser for an appraisal report must withhold EWT and issue BIR Form 2307.

What withholding tax rate applies when a client pays an individually licensed real estate appraiser directly? #

An individually licensed real estate appraiser is withheld at 5% (ATC WI010) if their gross income for the current year does not exceed ₱3,000,000 and a sworn declaration is on file, or 10% (ATC WI011) if it exceeds ₱3,000,000, the appraiser is VAT-registered, or no valid declaration has been submitted — the same individual professional-fee rate structure this series already applies to real estate brokers, architects, and engineers.

Does the rate change if the appraisal fee is paid to an appraisal corporation instead of the individual appraiser? #

Yes. If the payee is an appraisal firm organized as a corporation rather than the individual appraiser, the payment is a professional fee to a corporate payee, subject to 10% (ATC WC010) if the firm’s gross income for the current year does not exceed ₱720,000, or 15% (ATC WC011) if it exceeds ₱720,000.

What documents does a real estate appraiser need to submit to get the lower 5% rate? #

An individual appraiser claims the lower 5% rate by submitting an Income Payee’s Sworn Declaration of Gross Receipts/Sales (Annex B-1 for a single payor or Annex B-2 when income is split across multiple payors), together with a copy of their BIR Certificate of Registration, to each business that pays them, before the first payment of the year or at the start of the engagement.

Are insurance appraisers covered by the same named-professional withholding bracket? #

This guide focuses on real estate appraisers, who are clearly covered both as RA 9646-licensed real estate service practitioners and as the “professional appraisers” named in RR No. 2-98’s enumeration. Insurance adjusters and insurance agents, by contrast, sit in their own separate ₱720,000-threshold EWT item rather than the professional-fee bracket — see BIR Form 2307 for Insurance Agents and Adjusters for that distinct rate structure, so as not to conflate the two.

Summary #

A real estate appraiser clears the named-professional withholding test on two separate grounds: RA 9646 licensure as a real estate service practitioner, and direct enumeration as a “professional appraiser” under Section 2.57.2(A)(1) of RR No. 2-98. An individually licensed appraiser is withheld at 5%/10% (ATC WI010/WI011) once a sworn declaration is on file, while an appraisal firm organized as a corporation is withheld instead at 10%/15% (ATC WC010/WC011) based on its own gross income threshold. See BIR Form 2307 for Real Estate Brokers and Real Estate Service Practitioners for the shared RA 9646 basis and BIR Form 2307 for Architects and Engineers for the parallel individual-vs-firm structure applied to another named profession.