BIR Form 2307 for Marine and Cargo Surveyors: Withholding Rate and ATC Codes

A marine insurer, shipping company, or cargo owner that pays an individually engaged marine surveyor for a hull condition report or a cargo damage survey withholds tax under the same 5%/10% named-professional bracket as architects and geodetic engineers — because Revenue Regulations No. 2-98 names marine surveyors directly in its professional-fee enumeration, separately from general contractor or forwarding-service rates. The rate and ATC code turn on whether the payee is the individual surveyor or a marine surveying firm organized as a corporation.

This guide is part of the BIR Form 2307 series. It covers why marine surveyors are a named professional category, how the individual-vs-firm distinction changes the withholding rate, how this differs from a freight forwarder’s or customs broker’s bracket, and a worked cargo-damage survey example.

Are marine surveyors named professionals for withholding tax purposes? #

Yes — marine surveyors are individually listed in the same clause of RR No. 2-98 that names architects, engineers, and doctors of veterinary science, distinct from the flat 2% rate that applies to most general contractors. Section 2.57.2(A)(1) enumerates the individually engaged professionals subject to expanded withholding tax:

“…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

A marine surveyor inspects a vessel’s condition, surveys cargo for loading/discharge fitness, or assesses damage after an incident, typically at the request of a marine insurer, P&I club, shipowner, charterer, or cargo owner. Because the regulation names the profession specifically, a business paying an individually engaged marine surveyor for this work is paying a named professional, not a general contractor.

Individual surveyor or marine surveying firm — why the payee type changes the rate #

The ATC and rate depend on whether the actual payee is the individual marine surveyor or a marine surveying company organized as a corporation, following the same individual-vs-entity split this series covers for architects and engineers and geodetic engineers.

A marine insurer that engages “Capt. Reyes, Marine Surveyor” directly, billed under his own name and TIN, withholds at WI010/WI011. The same insurer paying an invoice from “Reyes Marine Survey & Consultancy, Inc.” for identical survey work withholds instead at WC010/WC011, because the invoice payee is a corporation. To secure the lower 5% individual rate, the surveyor files an Income Payee’s Sworn Declaration (Annex “B-1” or “B-2”) with the payor, the same mechanic covered in BIR Form 2307 for Professional Fees.

How this differs from a freight forwarder’s or customs broker’s bracket #

A marine surveyor’s inspection-and-report fee is a distinct, separately named professional service, not a forwarding arrangement fee or a customs brokerage fee — the three roles are withheld differently even though all three commonly appear on the same shipment. As BIR Form 2307 for Freight Forwarders and Customs Brokers explains, a licensed customs broker sits in the same 5%/10% named-professional bracket as a marine surveyor (both are individually enumerated professions), while a freight forwarding company’s arrangement fee typically falls under the flat 2% general contractor rate instead. A marine cargo insurer settling a claim commonly pays all three on one incident — the surveyor for the damage report, the broker for customs clearance, and the forwarder for arranging onward carriage — and each invoice needs its own ATC.

Who withholds on a marine surveyor’s fee #

Any business engaged in trade or business that pays a marine surveyor for services connected to that business — a marine insurer, shipping line, ship management company, or cargo owner — is a withholding agent and must withhold EWT before releasing payment. Common payors include:

• A marine and cargo insurer commissioning a survey to assess damage before settling a claim
• A P&I club or ship management company engaging a surveyor for a pre-purchase or condition survey
• A cargo owner or trading company retaining a surveyor to certify a bulk shipment’s quantity and condition before loading

An individual privately arranging a one-off personal survey outside any trade or business is not a withholding agent, following the same trade-or-business test applied throughout this series.

Worked example: a marine insurer’s cargo damage survey #

Pacific Marine Insurance Corp. engages Capt. Ernesto Villaruz, an individually engaged marine surveyor, for ₱60,000 to inspect and report on water damage to a container shipment before settling a client’s claim. Capt. Villaruz bills directly under his own name and TIN and has a sworn declaration (Annex B-1) on file confirming his gross income for the year has not exceeded ₱3,000,000, so ATC WI010 at 5% applies.

Pacific Marine remits the ₱3,000 withheld through BIR Form 0619-E monthly and BIR Form 1601-EQ quarterly, and issues a BIR Form 2307 showing ATC WI010 and the cumulative fees withheld, which Capt. Villaruz credits against his income tax due. Had the insurer instead engaged a corporation, “Villaruz Marine Surveyors, Inc.,” the same ₱60,000 fee would be withheld at 10% (ATC WC010), assuming the firm’s gross income for the year does not exceed ₱720,000 — ₱6,000 withheld under a corporate ATC instead.

Summary #

An individually engaged marine surveyor is withheld at 5%/10% (ATC WI010/WI011) under RR No. 2-98’s named-professional bracket, the same clause that covers architects, engineers, and geodetic engineers — a marine surveying firm organized as a corporation draws 10%/15% (ATC WC010/WC011) instead. This is a separate category from a freight forwarder’s flat 2% contractor rate and a customs broker’s own 5%/10% professional bracket, even though all three routinely appear on the same cargo claim. For the general professional-fee mechanics this scenario builds on, see BIR Form 2307 for Professional Fees, and for the parallel land-survey analysis, see BIR Form 2307 for Geodetic Engineers and Land Surveyors.