The BIR's Run After Fake Transactions (RAFT) Program: What It Targets and Why It Matters to You

Q: How is RAFT different from the BIR's RATE program?

The RATE (Run After Tax Evaders) program, covered separately on this site, pursues criminal prosecution for tax evasion generally. RAFT is narrower and specific to the ghost-receipt and fictitious-transaction scheme — it targets both the entities that sell fabricated receipts and the businesses that buy and use them, a distinct fact pattern from broader tax evasion cases RATE also covers.

Q: Is RAFT only about the sellers of fake receipts, or does it also target buyers?

Both. The BIR's enforcement under RAFT has pursued 'ghost corporations' that exist mainly to sell fictitious receipts, as well as the corporate buyers, officers, and even accounting professionals who knowingly use those receipts to claim deductions the underlying transactions never supported.

Q: What changed for RAFT in 2026?

Under Revenue Memorandum Circular No. 8-2026 and Revenue Memorandum Order No. 1-2026, both dated January 27, 2026, the BIR restructured how RAFT-related cases are handled, cancelling existing Letters of Authority tied to the prior task force structure and transferring RAFT investigation work to the National Investigation Division as part of the BIR's broader single-eLA audit framework overhaul.

Q: Can a business be penalized for simply having received a fake receipt from a supplier without knowing it?

The BIR's enforcement focus under RAFT is on knowing use of fictitious receipts to claim deductions — cases pursued so far have targeted buyers alongside sellers where the scale and pattern of transactions point to knowledge or willful blindness, not an isolated, good-faith purchase. Even so, a business that cannot substantiate a claimed expense with a legitimate, verifiable supplier faces disallowance of the deduction regardless of intent, which is why keeping real, traceable BIR Form 2307 and receipt records matters.

Run After Fake Transactions (RAFT) is the BIR’s enforcement program against ghost receipts — invoices for purchases or services that never happened, sold to businesses that use them to inflate deductible expenses and understate income tax due. Launched in 2023 and restructured in 2026, RAFT is distinct from the BIR’s older RATE (Run After Tax Evaders) and Oplan Kandado programs, and its buyer-side enforcement means the fake receipt itself is no longer where the risk stops.

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What does RAFT actually target? #

RAFT targets the trade in fictitious receipts and invoices — documents for goods or services that were never actually delivered or performed — used by businesses to manufacture deductible expenses that reduce reported taxable income. The scheme typically involves a “ghost corporation” or shell entity that exists mainly to issue receipts for purchases that never occurred, sold to legitimate operating businesses looking to lower their tax bill by claiming expenses they didn’t really incur.

The underlying criminal exposure for the sellers of these fake documents rests on NIRC Section 264, which penalizes a range of receipt-related violations. As reproduced in tax practitioner summaries of the provision:

Any person who commits any of the acts enumerated hereunder shall be penalized in the same manner and to the same extent as provided for in this Section: (1) Printing of receipts or sales or commercial invoices without authority from the Bureau…

Since RAFT’s 2023 launch under then-Commissioner Romeo D. Lumagui Jr., BIR enforcement has filed cases against dozens of taxpayers on both sides of these transactions — sellers of fake receipts, including several identified “ghost corporations” with assessed liabilities running into the tens of billions of pesos, and corporate buyers (along with, in some cases, their officers and outside accountants) who used the fabricated receipts. A widely reported 2024 case under this program involved a criminal referral against a major cosmetics company over an assessed liability of roughly ₱1.6 billion tied to allegedly fictitious purchases.

How is RAFT different from RATE and Oplan Kandado? #

RAFT, RATE, and Oplan Kandado are three separate BIR enforcement programs aimed at different fact patterns, and conflating them can lead a business to underestimate which one actually applies to its situation.

Program	Primary target
RAFT (Run After Fake Transactions)	Fictitious/ghost receipts used to fabricate deductible expenses
RATE (Run After Tax Evaders)	Broader criminal tax evasion cases across various schemes
Oplan Kandado	Business registration, invoicing, and bookkeeping violations found during compliance visits, which can lead to closure

RAFT is narrower than RATE in subject matter (it’s specifically about fake transactions, not tax evasion generally) but overlaps with it procedurally — a RAFT case can, and often does, proceed toward criminal referral the same way a RATE case would once the BIR has built its evidence.

What changed for RAFT in 2026? #

The BIR restructured how RAFT investigations are run as part of its broader 2026 audit overhaul, moving the work to a dedicated investigation unit rather than a standalone task force. Revenue Memorandum Circular No. 8-2026 and Revenue Memorandum Order No. 1-2026, both dated January 27, 2026 — the same package that introduced the BIR’s single-electronic-Letter-of-Authority (eLA) framework covered in BIR Tax Audits Resume in 2026 — cancelled Letters of Authority issued under the prior audit and task-force structure and folded RAFT-related investigation work into the National Investigation Division (NID). In practice, this means a business under RAFT scrutiny in 2026 deals with the NID rather than a separate, standalone task force, under the same single-eLA rules that now apply to BIR audits generally.

Why this matters even if you’ve never bought a fake receipt #

A business doesn’t need to have knowingly participated in a ghost-receipt scheme to feel the effect of heightened RAFT-era scrutiny — it means every claimed deduction needs a real, traceable paper trail, not just a receipt that looks correct on its face. As enforcement pursues both sellers and knowing buyers of fictitious transactions, the practical compliance takeaway for an ordinary business is to keep supplier relationships, BIR Form 2307 certificates, and underlying contracts or delivery records consistent and verifiable — not merely to hold a receipt, but to be able to show the transaction behind it actually happened.

Frequently asked questions #

What is the BIR’s RAFT program? #

Run After Fake Transactions (RAFT) is a BIR enforcement program, launched in 2023, that targets the buying and selling of fake or “ghost” receipts — invoices for purchases or services that never actually took place — used by taxpayers to inflate deductible expenses and understate income tax due.

How is RAFT different from the BIR’s RATE program? #

RATE pursues criminal prosecution for tax evasion generally. RAFT is narrower and specific to the ghost-receipt and fictitious-transaction scheme — it targets both the entities that sell fabricated receipts and the businesses that buy and use them.

Is RAFT only about the sellers of fake receipts, or does it also target buyers? #

Both. BIR enforcement under RAFT has pursued “ghost corporations” that exist mainly to sell fictitious receipts, as well as the corporate buyers, officers, and even accounting professionals who knowingly use those receipts.

What changed for RAFT in 2026? #

Under RMC No. 8-2026 and RMO No. 1-2026, both dated January 27, 2026, the BIR restructured how RAFT-related cases are handled, cancelling existing Letters of Authority tied to the prior task force structure and transferring investigation work to the National Investigation Division.

Can a business be penalized for simply having received a fake receipt from a supplier without knowing it? #

RAFT’s enforcement focus is on knowing use of fictitious receipts. Even so, a business that cannot substantiate a claimed expense with a legitimate, verifiable supplier faces disallowance of the deduction regardless of intent, which is why keeping real, traceable receipt records matters.

Summary #

RAFT targets the buying and selling of ghost receipts, is distinct from RATE (broader tax evasion) and Oplan Kandado (registration/invoicing violations), and moved to the National Investigation Division under the BIR’s 2026 audit restructuring. See What Is a BIR Letter of Authority? and BIR’s RATE Program for the related audit and enforcement context.