Does QAP Follow a Fiscal-Year Company's Own Quarters, or the Calendar Quarter?

No — QAP (the Quarterly Alphalist of Payees) stays on the standard calendar quarter even for a corporation that elected a fiscal year for its income tax return, because QAP attaches to BIR Form 1601-EQ or 1601-FQ, and those withholding tax returns run on calendar quarters for every withholding agent under Revenue Regulations (RR) No. 11-2018. This is the opposite of how SAWT behaves for the same fiscal-year company, which is exactly why the two filings can end up on different schedules for one taxpayer.

This post answers a question that trips up bookkeepers managing a mix of calendar-year and fiscal-year clients: once you know SAWT shifts to a fiscal-year taxpayer’s own quarters, it’s natural to assume QAP does too. It doesn’t, and this explains why.

Why doesn’t QAP move with a company’s fiscal year? #

QAP is legally an attachment to a withholding tax return — BIR Form 1601-EQ for expanded withholding or 1601-FQ for final withholding — and withholding tax returns are calendar-quarter filings for every withholding agent, regardless of what fiscal year that same agent elected for its own income tax. QAP Filing Deadlines already establishes the calendar-quarter pattern for ordinary filers under RR No. 11-2018: QAP is due on or before the last day of the month following the close of each calendar quarter, alongside the 1601-EQ or 1601-FQ it supports.

Nothing in RR No. 11-2018, or in any later issuance this site has found, carves out a fiscal-year exception for withholding tax returns. A company’s fiscal year under Section 43 of the National Internal Revenue Code (NIRC) is an election about when its own taxable year for income tax purposes begins and ends — it does not touch the separate calendar-quarter cycle that governs withholding tax remittance and the QAP attached to it.

Section 2.58 of Revenue Regulations No. 2-98, as amended by RR No. 11-2018, ties the alphalist attachment to the quarter of the withholding tax return itself, not to any taxpayer-specific accounting period:

“The return filed shall be accompanied by the Quarterly Alphabetical List of Payees (QAP), reflecting the name of income payees, Taxpayer Identification Number (TIN), the amount of income paid segregated per month with total for the quarter, and the total amount of taxes withheld, if any.”

— Section 2.58, Revenue Regulations No. 2-98, as amended by Revenue Regulations No. 11-2018, as quoted in tax-practitioner commentary summarizing the regulation

The provision ties QAP to “the quarter” of the withholding return as a fixed, regulation-defined period — the same calendar quarter the return itself runs on — with no cross-reference to a filer’s elected fiscal year anywhere in the withholding tax rules.

Why is SAWT different? #

SAWT attaches to the income tax return itself — 1701Q, 1702Q, 1701, or 1702 — and a corporation’s income tax return due dates are computed from its own elected fiscal quarters, which is why SAWT shifts for a fiscal-year filer while QAP does not. SAWT DAT File Deadlines for Fiscal-Year Taxpayers explains this mechanic in full: because Revenue Regulations No. 2-2006 ties SAWT to the return claiming the CWT credit, and that return’s due date is fiscal, SAWT’s due date is fiscal too.

The table below puts the two side by side for the same hypothetical fiscal-year company, so the contrast is visible in one place:

Worked example: Meridian Fiscal Corp., fiscal year ending March 31 #

Using the same fictional company from this site’s SAWT fiscal-year coverage shows exactly how far apart the two schedules can be for one taxpayer. Meridian Fiscal Corp. elected a fiscal year running April 1 to March 31 under BIR Form 1905. Its SAWT-bearing income tax returns fall due on fiscal dates — August 29, November 29, March 1, and July 15, as laid out in SAWT DAT File Deadlines for Fiscal-Year Taxpayers. Its QAP, by contrast, runs on the ordinary calendar regardless of any of that:

Meridian’s finance team files a 1601-EQ and QAP every calendar quarter on the dates above, completely independent of its March 31 fiscal year-end — while its 1702Q and SAWT follow the fiscal dates covered in the SAWT post. A bookkeeper who assumes “this client is on a fiscal year, so everything shifts” will misfile QAP on the wrong date; QAP never shifted in the first place.

What should a bookkeeper actually track for a fiscal-year client? #

Two separate calendars, not one. For a fiscal-year corporation:

1. Track QAP and 1601-EQ/1601-FQ on the standard calendar quarters — April 30, July 31, October 31, and January 31 — exactly as for any calendar-year client.
2. Track SAWT and 1701Q/1702Q/1701/1702 on the company’s own fiscal quarters, computed from its BIR Form 1905 accounting-period election.
3. Don’t let one filing’s fiscal shift bleed into the other — a fiscal-year client doesn’t get a single unified “fiscal filing calendar” across every BIR obligation; each filing follows the rule for the return it’s actually attached to.
4. Confirm the fiscal year-end on file before building either calendar, since an incorrect assumption here cascades into both the SAWT and QAP schedules differently.

Frequently asked questions #

Does a fiscal-year corporation’s QAP deadline move with its fiscal quarters? #

No. QAP is an attachment to BIR Form 1601-EQ or 1601-FQ, the expanded and final withholding tax returns, which Revenue Regulations No. 11-2018 ties to the standard January-to-December calendar quarters for every withholding agent — regardless of whether that same company elected a different fiscal year for its own income tax return.

Why is QAP different from SAWT on this point? #

SAWT attaches to the taxpayer’s income tax return (1701Q, 1702Q, 1701, or 1702), and a corporation’s income tax return due dates are computed from its own elected fiscal quarters under Section 43 of the NIRC. QAP attaches to the withholding tax return instead, and withholding tax returns are calendar-quarter returns for every withholding agent, so QAP never inherits a fiscal-year shift the way SAWT does.

If my company has a March 31 fiscal year-end, when is QAP due? #

The same four calendar-quarter dates as any other withholding agent: April 30 for Q1 (Jan–Mar), July 31 for Q2 (Apr–Jun), October 31 for Q3 (Jul–Sep), and January 31 of the following year for Q4 (Oct–Dec) — your fiscal year-end date has no bearing on these dates.

Does this mean a fiscal-year company files QAP and SAWT on different schedules? #

Yes, and that is the single most important thing for a bookkeeper managing a fiscal-year client to internalize: QAP always follows the standard calendar-quarter withholding deadlines, while SAWT follows that same company’s fiscal-quarter income tax deadlines. The two DAT filings are not synchronized for a fiscal-year taxpayer, even though they often are for a calendar-year one.

Summary #

QAP never shifts for a fiscal-year taxpayer because it attaches to the withholding tax return (1601-EQ/1601-FQ), and withholding tax returns run on the standard calendar quarter under RR No. 11-2018 for every withholding agent. SAWT, by contrast, attaches to the income tax return and does shift to a fiscal-year company’s own quarters. The two filings’ schedules diverge precisely because of what each one is legally attached to — not because one rule is stricter than the other. For the calendar-quarter QAP mechanics, see QAP Filing Deadlines; for the fiscal-year SAWT mechanics this post contrasts against, see SAWT DAT File Deadlines for Fiscal-Year Taxpayers.