BIR Form 2307 for Billboard and Outdoor Advertising Rental: 5% Site Lease, Not the 2% Media-Buying Rule

A brand that rents a specific billboard structure or outdoor advertising site from an out-of-home (OOH) media owner withholds 5% expanded withholding tax (EWT) on the rental, under Revenue Regulations (RR) No. 11-2018 — the same rental bracket that covers office space, equipment, and vehicles, because RR No. 11-2018 explicitly folds billboards and similar structures into it. This is a different rule from the 2% withholding chain that applies when a company instead buys outdoor ad placements through a media-buying or advertising agency.

This guide is part of the BIR Form 2307 series. It explains why site rental and media placement get different withholding treatment, how to split a bundled OOH invoice that itemizes a service fee alongside the rent, and a worked EDSA billboard example.

Is a billboard payment rental or a media placement? #

The test is what the brand actually contracted for: exclusive use of a specific, identified billboard structure or site under a lease is rental at 5%; buying ad space or time as part of a media campaign booked through the advertiser-media-agency chain is a media placement at 2%. Both involve “outdoor advertising” in a loose commercial sense, but BIR Form 2307 tracks the substance of the contract, not the marketing label on the invoice — the same principle covered in BIR Form 2307 for Co-Working and Virtual Office Providers, where exclusive possession of a specific space is what separates a 5% lease from a 2% service.

A brand that signs a lease with an OOH media owner for a named, numbered structure — “Billboard Unit 14, EDSA Northbound, Guadalupe” — occupied to the exclusion of anyone else for the term of the contract, is renting real or personal property. A brand that instead instructs a media-buying agency to “run an outdoor campaign” across a rotating set of sites the agency selects and books on its behalf, as part of a broader multi-channel plan, is buying a media placement.

Why does billboard site rental fall under the 5% rule? #

RR No. 11-2018 amended RR No. 2-98’s rental withholding category to expressly include billboards and similar advertising structures alongside real property, so a direct billboard site lease is withheld the same way office or warehouse rent is. This is the same 5% bracket covered in Withholding Tax on Rent, just extended to a specific structure type.

Tax-practitioner overviews of RR No. 2-98, as amended by RR No. 11-2018, consistently render the operative rental clause this way (the BIR’s own regulation text was not independently accessible for this article, so treat this as a secondary-sourced rendering rather than a primary-document confirmation):

“On gross rentals or lease of spaces used in posting advertisements in the form of billboards and/or structures similar thereto, posted in public places — Five percent (5%).”

— Section 2.57.2(C), RR No. 2-98, as amended by RR No. 11-2018, as rendered in tax-practitioner digests of the regulation

Because the clause sits inside the same rental subsection that covers real property and equipment leases, a billboard site lease is withheld exactly like any other rental payment: 5% on the gross amount, no minimum threshold, using the standard rental ATC codes.

How does RMC No. 63-2012’s media-buying rule differ? #

RMC No. 63-2012 governs a different transaction entirely: an advertiser paying a media supplier — which can include an outdoor media owner — for ad placement booked through the tripartite advertiser-media supplier-advertising agency structure, at 2%, not 5%. The circular addresses invoicing and withholding across that three-party chain so an agency’s commission isn’t withheld on twice. As covered in BIR Form 2307 for Advertising Agencies and Media Placements, the advertiser withholds 2% on the full amount it pays the media supplier, which can be a TV network, radio station, digital platform, or an outdoor media owner selling placement as part of a campaign — and the media supplier separately withholds 2% when it pays the agency’s commission.

The distinction that matters for BIR Form 2307 purposes is what the outdoor media owner is actually selling:

An outdoor media owner can genuinely operate in both modes — leasing specific structures directly to some clients while also selling rotating placement inventory through media-buying agencies to others. What governs a given payment is the contract actually signed, not the OOH company’s general business description.

Splitting a bundled OOH invoice: rental versus service #

When an OOH company itemizes a separate printing, production, or ongoing maintenance fee alongside the site rental, that service component can fall under the 2% general-services bracket instead of the 5% rental rate — the same split-billing logic applied to bundled co-working invoices. A billboard lease often includes more than bare site access: printing and mounting the tarpaulin or LED content, periodic cleaning, and structural maintenance. If the OOH company’s invoice or contract separately states a fixed monthly or per-campaign amount for that service work, distinct from the site rental itself, withhold 5% on the rental line and 2% on the service line.

If the invoice does not separate the two — a single lump-sum “billboard package” fee with no itemized breakdown — the more defensible default is to withhold 5% on the full amount, since the underlying contract is still fundamentally a site lease with incidental services bundled in, not a standalone service contract. Ask the OOH company for an itemized billing before assuming a split is available; do not estimate a percentage split on your own.

Which ATC code applies to a billboard rental payment? #

Billboard site rentals use the same rental ATC codes as any other lease: WC100 for a corporate billboard owner, WI100 for an individual or sole proprietor owner. If a service component is separately billed and withheld at 2%, that portion uses the general contractor/service codes — WC120/WI120 if billed as a contracted service, consistent with the codes covered in Contractors and Subcontractors.

Worked example: a 12-month EDSA billboard lease #

Suppose a consumer brand leases a single EDSA billboard structure from a corporate OOH media owner for 12 months at ₱150,000 per month, under a lease naming the specific structure and giving the brand exclusive display rights for the term.

The brand issues BIR Form 2307 each period (or a single certificate covering the year, per its issuance practice) showing ₱150,000 as the monthly income payment, ATC WC100, and ₱7,500 as tax withheld.

Variant — bundled invoice with a separately itemized service fee. Suppose the same OOH company also handles content printing and monthly structural maintenance, and itemizes this as a separate ₱20,000 per month production/maintenance fee on the same invoice, distinct from the site rental:

The brand now issues BIR Form 2307 showing two separate income-payment lines — ₱150,000 under ATC WC100 and ₱20,000 under ATC WC120 — rather than treating the full ₱170,000 as a single rental amount.

Frequently asked questions #

Is billboard rental subject to 5% or 2% withholding tax? #

Renting a specific billboard structure or outdoor advertising site under a lease is subject to 5% expanded withholding tax under Revenue Regulations No. 11-2018, which amended RR No. 2-98 to bring billboards and similar structures into the same rental category as real property. This is different from paying a media supplier to buy ad placements as part of a campaign, which falls under the 2% media-buying rule in RMC No. 63-2012.

What is the difference between renting a billboard site and buying outdoor ad placement through a media agency? #

Renting a billboard site means a brand contracts directly with an out-of-home media owner for exclusive use of a specific, identified structure or space for a fixed term — this is a lease, taxed at 5%. Buying outdoor ad placement through a media-buying or advertising agency means the agency books space on the advertiser’s behalf as part of a broader campaign under the advertiser-media-agency chain RMC No. 63-2012 governs, taxed at 2% on the media supplier’s invoice.

Which ATC code applies to billboard rental payments on BIR Form 2307? #

ATC WC100 applies when the billboard or outdoor media owner is a corporation, and ATC WI100 applies when the owner is an individual or sole proprietor, both at the 5% rental rate under RR No. 11-2018 — the same codes used for any other real or personal property rental.

Do I need to split withholding if the OOH company bills a bundled production and maintenance fee together with the site rent? #

Yes, if the out-of-home company itemizes the production, printing, or maintenance service as a separate line from the site rental on its invoice. Withhold 5% on the rental portion and 2% on the separately billed service portion. If the invoice does not itemize the two, the safer practice is to withhold 5% on the full bundled amount, treating the service as incidental to the lease.

Does RMC No. 63-2012 apply to billboard rentals? #

Not to a direct lease of a billboard structure or site. RMC No. 63-2012 governs the advertiser-media supplier-advertising agency chain for buying media placements — TV, radio, print, digital, or outdoor ad slots booked as part of a campaign. A brand that leases a specific billboard site directly from its owner, with exclusive use of that structure for a term, is renting real or personal property under RR No. 11-2018, not buying a media placement.

What withholding tax form does the advertiser file after withholding on a billboard lease? #

The advertiser remits the withheld amount using BIR Form 0619-E monthly and BIR Form 1601-EQ quarterly, reports the billboard owner on its Quarterly Alphalist of Payees, and issues BIR Form 2307 to the billboard owner as proof of the tax withheld for that owner to credit against its own income tax due.

Summary #

A billboard or outdoor advertising payment is not automatically a “media” expense for withholding purposes — what matters is whether the brand is leasing a specific, exclusively-used structure (5% rental under RR No. 11-2018, ATC WC100/WI100) or buying placement through a media-buying chain covered by RMC No. 63-2012’s 2% rule. When an OOH company bundles a separately itemized production or maintenance service fee with the site rent, split the withholding: 5% on the rental line, 2% on the service line, using the OOH company’s own itemized billing rather than an assumed split. Getting this distinction right on BIR Form 2307 keeps the certificate matching cleanly against both the advertiser’s alphalist and the billboard owner’s tax credit claim; see Withholding Tax on Rent and What Is BIR Form 2307 for the underlying rules this guide builds on.