BIR Form 2307 for Tattoo, Piercing, and Permanent Makeup Studios

A corporate client that books an individual tattoo artist as promotional talent — say, a live tattoo or henna activation at a product launch — generally withholds 5% or 10% under RR No. 11-2018’s talent-fee bracket. A company that instead contracts a tattoo, piercing, or permanent makeup (PMU) studio as a registered business withholds 2% under the general business-services bracket of RR No. 2-98. A walk-in customer paying the same studio for a personal tattoo, piercing, or PMU session out of pocket triggers no withholding at all. Which treatment applies turns on two separate questions: is the payor a business, and is the payee an individual artist or a registered studio.

This guide is part of the BIR Form 2307 series. It covers the business-to-business (B2B) vs. business-to-consumer (B2C) line that decides whether withholding applies at all, the separate individual-artist-vs-studio-business distinction that decides which rate applies, the ATC codes involved, and a worked example contrasting a corporate promo booking with a routine walk-in session.

When does a tattoo, piercing, or PMU payment get withheld at all? #

Withholding only attaches when the payor is itself a business — a corporation, or an individual engaged in trade or business paying in the course of that business — never when an individual client pays for a personal tattoo, piercing, or cosmetic-tattooing session out of pocket. RR No. 2-98 frames the withholding-agent test around the payor’s own status, not the service performed:

“(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 tattoo, piercing, and PMU engagements, this is exactly the same B2B-vs-B2C line already covered in this series for freelance makeup artists and for barbershops, salons, and spas:

• A beverage, apparel, or lifestyle brand booking a tattoo artist to do a branded activation at a launch event is a withholding agent under clause (A), regardless of company size.
• A spa chain, wellness clinic, or corporate wellness program that contracts a PMU studio to provide microblading or lip-blush services to staff or members under a recurring arrangement is likewise a withholding agent, because it is paying in the course of its own business.
• An individual walk-in client — the overwhelming majority of tattoo, piercing, and PMU transactions — paying out of personal funds for their own tattoo, ear piercing, or microblading session falls outside clause (B): no trade or business connection, no withholding, no BIR Form 2307.

This is the crux most tattoo and PMU businesses actually need to resolve before worrying about rates at all: almost every retail transaction a studio runs is B2C and generates no BIR Form 2307 whatsoever. The form only enters the picture once a business — not a consumer — is the one paying.

Individual artist as promotional talent vs. studio as a business #

Once a business payor is confirmed, the next question is who exactly is being paid: an individual artist engaged directly, or a studio operating as a registered business entity. That distinction decides which withholding bracket applies, and it tracks the same professional-fee-vs-business-income split this series already documents for talent fees and for salon/spa chair arrangements.

• An individual tattoo artist booked directly for a promotional or advertising appearance — a live-tattoo or henna booth at a brand activation, a public demonstration for a product launch, or a paid appearance tied to sales promotion — falls under RR No. 11-2018’s “other recipients of talent fees” category, the same bracket this series covers for entertainers and athletes: 5% (ATC WI080) if the artist has a sworn declaration and BIR Certificate of Registration on file and current-year gross income at or under ₱3,000,000, or 10% (ATC WI081) otherwise.
• A tattoo, piercing, or PMU studio paid as a business — because the payment covers its artists, space, and equipment collectively rather than one individually engaged talent, and because the engagement is an ordinary service contract rather than a promotional appearance — generally falls under the 2% general contractor/business-services bracket under RR No. 2-98, Section 2.57.2(E), as amended by RR No. 11-2018, using ATC WI120 (individual/sole proprietor) or WC120 (corporation).
• An individual artist engaged for ordinary contracted work that isn’t a promotional or advertising appearance — for example, a company hiring a freelance PMU artist to do a one-off custom job unrelated to any brand activation — more often sits under the general individual professional-fee bracket (ATC WI010 at 5%, WI011 at 10%) instead of the talent-specific codes, the same care this series flags against defaulting entertainers to the wrong ATC.

Worked example: a corporate promo booking vs. a walk-in studio session #

Horizon Beverages Inc. books independent tattoo artist Mico Santos to run a branded temporary-tattoo activation booth at its product-launch event for a flat ₱25,000. Mico has a sworn declaration (Annex “B-1”) and BIR Certificate of Registration on file, is non-VAT registered, and his current-year gross income is well under ₱3,000,000, so ATC WI080 at 5% applies:

Horizon Beverages remits the ₱1,250 through BIR Form 0619-E monthly and BIR Form 1601-EQ quarterly, lists Mico on its Quarterly Alphalist of Payees, and issues him a BIR Form 2307 showing ₱25,000 as the income payment, ATC WI080, and ₱1,250 tax withheld. Had Mico not filed the sworn declaration, ATC WI081 at 10% would apply instead, withholding ₱2,500 — the same booking, double the tax withheld, purely because of the missing paperwork.

Separately, a walk-in customer pays Inked Canvas Tattoo Studio ₱3,500 out of pocket for a personal forearm tattoo. The customer is not engaged in trade or business with respect to that payment, so RR No. 2-98, Section 2.57.3(B) doesn’t reach it — no withholding, no BIR Form 2307. Inked Canvas simply issues an official receipt. If instead a spa chain contracts Inked Canvas Studio — now acting as the registered business, covering several artists and a booth — to run a recurring brand-activation residency at ₱80,000 a month, that payment falls under the 2% service-contract bracket (ATC WI120 for a sole proprietorship), withholding ₱1,600 per month rather than the talent-fee rate, because the payment covers the studio’s business operations rather than one individually engaged artist.

Why permanent makeup studios aren’t quite the mobile-HMUA case #

PMU work — microblading, lip blush, and similar semi-permanent cosmetic tattooing — shares a payor-status test with the mobile hair-and-makeup artists already covered in this series, but the typical business shape differs. A mobile HMUA artist usually travels to a client or set and bills as one individually engaged freelancer, which is why that guide’s worked example centers on a single production-company-vs-bride comparison. Tattoo, piercing, and PMU services, by contrast, more often run out of a fixed studio location with multiple artists sharing space, tools, and a single business registration — closer in shape to the salon and spa businesses already covered in this series. That’s why a corporate client paying a tattoo or PMU studio is more likely to land in the 2% business-services bracket than the individual talent-fee bracket, unless the business specifically books one named artist for a standalone promotional appearance, as in the worked example above.

Frequently asked questions #

Does a tattoo, piercing, or permanent makeup studio need to deal with BIR Form 2307? #

Only when a business — not an individual walk-in client — pays for the service. A corporate client booking an individual tattoo artist for a promotional appearance, or a company contracting a tattoo, piercing, or PMU studio as a registered business under a recurring arrangement, is a withholding agent and must withhold tax and issue BIR Form 2307.

What withholding tax rate applies when a company books an individual tattoo artist for a corporate event or promotion? #

Under RR No. 11-2018, an individual booked for a promotional appearance or public demonstration tied to advertising or sales promotion generally falls under the other-recipients-of-talent-fees bracket — 5% (ATC WI080) with a sworn declaration and Certificate of Registration on file and current-year gross income at or under ₱3,000,000, or 10% (ATC WI081) without a declaration or above that threshold.

What rate applies when a company pays a tattoo, piercing, or PMU studio as a registered business? #

A service-contract payment to a studio operating as a business — covering its artists, space, and equipment collectively rather than one individually engaged artist — generally falls under the 2% general contractor/business-services bracket under RR No. 2-98, Section 2.57.2(E), as amended by RR No. 11-2018, using ATC WI120 (individual/sole proprietor) or WC120 (corporation).

Does a walk-in customer paying for a tattoo or piercing trigger withholding tax? #

No. Withholding under RR No. 2-98 applies only when the payor is a business or an individual engaged in trade or business paying in the course of that business. A walk-in customer paying out of pocket for a personal tattoo, piercing, or cosmetic-tattooing session is not a withholding agent, so no BIR Form 2307 is issued.

How is this different from the BIR Form 2307 treatment for mobile makeup artists? #

The underlying test is the same — payor status decides whether withholding applies at all — but tattoo, piercing, and PMU work more often happens at a fixed studio with several artists operating as one registered business, while mobile hair-and-makeup services are typically billed by a single individually engaged freelancer. That’s why a studio booking is more likely to land in the 2% business-services bracket, while an individual artist booked directly, especially for a promotional appearance, falls under the individual talent-fee bracket instead.

Summary #

Whether BIR Form 2307 applies to a tattoo, piercing, or PMU payment turns on two separate questions. First, is the payor a business at all — a walk-in client paying out of pocket never triggers withholding under RR No. 2-98, Section 2.57.3(A)–(B), no matter how the artist or studio is organized. Second, once a business is paying, is the payee an individual artist booked as promotional talent (5%/10% under RR No. 11-2018, ATC WI080/WI081) or a studio operating as a registered business under a service contract (2% under RR No. 2-98, Section 2.57.2(E), ATC WI120/WC120). See BIR Form 2307 for Freelance Makeup Artists and HMUA Services for the closely parallel individual-artist-vs-private-client split, BIR Form 2307 for Talent Fees for the full talent-fee ATC structure, and BIR Form 2307 for Barbershops, Salons, and Spas for the closest analogous business-vs-individual-provider distinction.