BIR Form 2307 for Drone Pilots: Aerial Photography, Videography, and Mapping

A business that pays a freelance drone pilot for aerial photography, videography, or mapping footage generally withholds 2% expanded withholding tax (EWT) and issues BIR Form 2307 — the same general business-services bracket that already applies to ground-based photographers and videographers on this site. That changes only in one narrow case: when the drone operator is also a PRC-licensed geodetic engineer performing an official land survey, where the fee shifts to the 5%/10% professional bracket instead.

This guide is part of the BIR Form 2307 series. It covers why aerial imaging and mapping services aren’t on RR No. 11-2018’s named-professional list, the ATC codes involved, the licensed-surveying exception, and a worked example contrasting a marketing shoot with an engineer’s drone-assisted survey.

Who withholds on a drone pilot’s service fee? #

As with any other business-service supplier, the withholding obligation tracks the payor’s status, not the type of equipment used to render the service. RR No. 2-98 defines a withholding agent 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)

Applied to drone-based aerial services:

• A real estate developer paying a drone pilot to film a subdivision, a marketing agency commissioning aerial brand footage, or a construction firm hiring a drone operator for progress-monitoring shots is a withholding agent under clause (A), regardless of company size.
• An event organizer or agency that engages and pays a drone pilot directly — even to cover someone else’s event — is the withholding agent on that specific payment, because it is itself a business paying in the course of its operations.
• A private individual paying a drone pilot to film their own family event or personal property out of personal funds, with no business behind the payment, falls outside clause (B) — no trade or business connection, no withholding, no BIR Form 2307.

This is the same payor-status test this series covers in BIR Form 2307 for Photographers and Videographers — a drone pilot shooting aerial marketing footage and a ground-based videographer are withheld from under identical logic, because both sit inside the same general business-services bracket once a business, rather than a private individual, is paying.

Is a drone pilot a named professional under RR No. 11-2018 — or a general service provider? #

RR No. 11-2018 restructured RR No. 2-98’s Section 2.57.2(A) into a specific enumeration of PRC-licensed professions subject to the 5%/10% withholding bracket, and drone piloting or aerial imaging is not one of them. The enumeration reads:

“…the following individuals shall be subjected to expanded withholding tax: …architects[,] civil, electrical, chemical, mechanical, structural, industrial, mining, sanitary, metallurgical, geodetic engineers…”

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

That list covers doctors, lawyers, CPAs, architects, and named engineering disciplines — including geodetic engineers, whose licensed work is land surveying. A freelance drone operator shooting aerial photography, videography, or general mapping footage is not practicing a PRC-licensed profession; operating a drone requires a CAAP controller certificate and authorization for the flight itself, not a professional license from the Professional Regulation Commission. Because that service isn’t named in the enumeration, it falls under BIR Form 2307 for Contractors and Subcontractors’ flat 2% general contractor/business-services catch-all instead — the same bracket this series already applies to photographers, videographers, and other creative-service suppliers not given a more specific rate.

The one exception is a PRC-licensed geodetic engineer using a drone as a survey tool. If the engagement is specifically for licensed surveying work — producing an official land survey, boundary plan, or subdivision plan — the fee is that engineer’s professional fee, not a generic aerial-imaging fee, and it falls under the 5%/10% (individual) or 10%/15% (corporate survey firm) professional bracket regardless of whether the survey data was captured by a drone, a total station, or GPS equipment. The drone is simply the instrument; the licensed profession behind the output is what decides the rate.

Worked example: aerial marketing footage vs. a licensed land survey #

Skyline Vista Realty Corporation, a real estate developer, hires Marco Reyes, a freelance drone operator, to shoot aerial marketing footage of its new subdivision for ₱25,000 (a single project fee). Marco is not a PRC-licensed engineer — he holds a CAAP controller certificate and delivers drone photography and video for marketing use. Because Skyline Vista is a corporation paying for a business marketing deliverable, it withholds under the general 2% bracket:

Skyline Vista remits the ₱500 through BIR Form 0619-E monthly and BIR Form 1601-EQ quarterly, lists Marco on its Quarterly Alphalist of Payees, and issues him a BIR Form 2307 showing ₱25,000 as the income payment, ATC WI120, and ₱500 tax withheld. Marco credits the ₱500 against his own income tax due for the period.

Contrast this with Vantage Land Surveys Corp., hired by a construction firm to conduct an official boundary survey for a new subdivision, using drone-based photogrammetry in place of a traditional ground survey to speed up data capture. The engagement is performed and certified by a PRC-licensed geodetic engineer as part of a licensed surveying service — the output is a certified survey/subdivision plan, not marketing footage. Because the fee is for licensed professional surveying work, the construction firm withholds under the professional-fee bracket instead: 10% (ATC WC010) if Vantage’s gross income for the year does not exceed ₱720,000, or 15% (ATC WC011) above that threshold — not the 2% general-services rate that applied to Marco’s marketing shoot, even though both jobs involved a drone.

Frequently asked questions #

Does a company have to withhold tax when paying a drone pilot for aerial photos or video? #

Yes, if the payor is a corporation or an individual paying in the course of trade or business. A real estate developer, marketing agency, or other business paying a drone pilot for aerial photography, videography, or mapping footage under RR No. 2-98, Section 2.57.3(A)-(B) is a withholding agent and must withhold expanded withholding tax and issue BIR Form 2307.

What withholding tax rate applies to a drone pilot’s service fee? #

A drone pilot’s aerial photography, videography, or mapping fee generally falls under the flat 2% general contractor/business-services bracket under RR No. 2-98, Section 2.57.2(E) — ATC WI120 for an individual freelance drone operator, WC120 for a drone services company organized as a corporation — because aerial imaging is not on RR No. 11-2018’s enumerated list of PRC-licensed professions.

Is a drone pilot considered a licensed professional for withholding tax purposes? #

No, not by default. RR No. 2-98, Section 2.57.2(A), as restructured by RR No. 11-2018, names specific PRC-licensed professions subject to the 5%/10% professional-fee bracket — doctors, lawyers, CPAs, architects, and each named engineering discipline including geodetic engineers. Piloting a drone and shooting aerial footage is not itself a PRC-licensed profession, so the fee defaults to the 2% general-services bracket instead.

When would a drone operator’s fee fall under the 5%/10% professional bracket instead of 2%? #

Only when the drone operator is also a PRC-licensed geodetic engineer and the fee is specifically for a licensed surveying engagement — for example, drone-based photogrammetry used to produce an official land survey or subdivision plan. In that case the fee is withheld as a geodetic engineer’s professional fee under RR No. 11-2018, at 5%/10% for an individual or 10%/15% for a survey firm organized as a corporation, not at the general 2% rate.

Does a drone pilot need a CAAP permit, and does that affect the withholding rate? #

A drone pilot operating commercially in the Philippines generally needs authorization from the Civil Aviation Authority of the Philippines (CAAP), separate from BIR registration. CAAP authorization governs whether the flight itself is legal; it has no bearing on which BIR withholding tax rate applies to the service fee, which turns on the nature of the engagement under RR No. 2-98, not on aviation permits.

Summary #

A drone pilot’s aerial photography, videography, or general mapping fee sits in the same 2% general business-services bracket (ATC WI120/WC120) as ground-based photographers and videographers under RR No. 2-98, Section 2.57.2(E), because aerial imaging is not on RR No. 11-2018’s enumerated list of PRC-licensed professions. That changes only when a PRC-licensed geodetic engineer performs drone-assisted surveying work as part of a licensed engagement — that fee is withheld under the engineer’s own 5%/10% (individual) or 10%/15% (corporate) professional bracket instead, same as any other named professional. What decides the rate isn’t the drone; it’s whether a PRC-licensed profession, not just a CAAP flight authorization, is actually behind the output. See BIR Form 2307 for Photographers and Videographers for the closely parallel general-services reasoning, and BIR Form 2307 for Professional Fees for how the 5%/10%/10%/15% professional bracket works across every other named profession.