Which Alphalist Does a Government Money Payments (GMP) Withholding Agent File: QAP or Something Else?

A national government agency (NGA), GOCC, or LGU that withholds tax on a Government Money Payment (GMP) files the same Quarterly Alphalist of Payees (QAP) that any other withholding agent files — there is no separate, government-only alphalist. GMP withholding is a distinct set of rates and ATC codes, not a distinct filing regime. The QAP DAT file attaches to BIR Form 1601-EQ under Revenue Regulations No. 11-2018, the same rule that governs every creditable-withholding filer, and it runs alongside — not instead of — the BIR Form 2307 certificate issued to each supplier.

This confusion is common because GMP withholding already has its own rates, its own ATC codes, and its own worked examples elsewhere on this site — it’s easy to assume a specialized withholding category needs a specialized alphalist too. It doesn’t. This guide walks through why QAP covers GMP withholding agents like any other, how QAP and BIR Form 2307 fit together for the same disbursement, and a worked example from an LGU treasurer’s office.

What alphalist applies to a GMP withholding agent, and why isn’t there a separate one? #

QAP (Quarterly Alphalist of Payees) is the single DAT-file listing every withholding agent uses to report the payees it withheld creditable tax from during the quarter, and Government Money Payments withholding agents are withholding agents like any other for this purpose. Revenue Regulations No. 11-2018, amending Section 2.58 of RR No. 2-98, sets QAP as a mandatory attachment to BIR Form 1601-EQ for creditable (expanded) withholding tax. It does not carve out a separate rule, form, or filing channel for national government agencies, GOCCs, or LGUs — the requirement is written around the act of withholding creditable tax, not around who is doing the withholding.

The regulation’s own language, describing what the QAP attachment must contain, states it plainly:

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

Nothing in that description references the payor’s identity. A city engineering office, a national line agency, or a private manufacturing corporation withholding the same type of tax all file the same QAP, in the same layout, on the same schedule. What’s specific to GMP withholding is covered separately in BIR Form 2307 for Government Money Payments — the government-specific 1%/2% creditable income tax rate and ATC codes (WC640/WI640 for goods, WC157/WI157 for services), plus the 5% creditable VAT withholding under Revenue Memorandum Circular No. 36-2021. Those rates and codes feed into the standard QAP; they don’t require a QAP substitute.

How does QAP fit with BIR Form 2307 for the same GMP payment? #

QAP and BIR Form 2307 report the same underlying withholding from two different angles, and a GMP withholding agent files both — QAP is the withholding agent’s own quarterly summary to the BIR, while BIR Form 2307 is the individual certificate handed to each supplier. Confusing the two, or assuming one replaces the other, is the more common mistake than assuming GMP needs its own alphalist.

A GMP withholding agent’s quarterly workflow is not “QAP or BIR Form 2307” — it’s both, built from the same underlying payment data. The QAP DAT file should list exactly the payees who also received a BIR Form 2307 for that quarter; a payee on one but missing from the other is a reconciliation gap worth catching before either is submitted.

Worked example: an LGU treasurer’s office pays a supplier ₱500,000 for office supplies #

A municipal treasurer’s office buying office supplies from a local, non-VAT-registered supplier illustrates how one GMP payment produces one QAP entry and one BIR Form 2307 — not two separate filing tracks. Suppose the office purchases ₱500,000 worth of office supplies for the quarter from a supplier not registered for VAT.

The treasurer’s office does two things with this transaction, not one:

1. Issues BIR Form 2307 to the supplier for the ₱5,000 withheld, which the supplier later uses to credit against its own income tax due.
2. Includes the supplier’s TIN, name, the ₱500,000 income payment, and the ₱5,000 tax withheld as one row in that quarter’s QAP DAT file, filed with BIR Form 1601-EQ.

If the same office makes similar 1% or 2% withholding payments to a dozen other suppliers in the same quarter, each one becomes its own BIR Form 2307 and its own row in the same single QAP file — one file, not one per supplier. That’s the practical benefit of QAP being a bulk alphalist rather than a per-transaction filing: a treasurer’s office reconciling many suppliers against one quarterly return needs the totals across every row to match what was actually remitted on BIR Form 1601-EQ, which is exactly the kind of manual cross-checking that gets error-prone once supplier counts climb into the dozens.

What happens if a GMP withholding agent’s QAP is late or wrong? #

A late or missing QAP is treated the same as any other missed information return — it carries the Section 250 NIRC penalty regardless of whether the withholding agent is a private company or a government office. The National Internal Revenue Code sets the base penalty in plain terms:

“In the case of each failure to file an information return, statement or list, or keep any record, or supply any information required by this Code or by the Commissioner on the date prescribed therefor, unless it is shown that such failure is due to reasonable cause and not to willful neglect, there shall, upon notice and demand by the Commissioner, be paid by the person failing to file, keep or supply the same, One thousand pesos (P1,000) for each such failure: Provided, That the aggregate amount to be imposed for all such failures during a calendar year shall not exceed Twenty-five thousand pesos (P25,000).”

— National Internal Revenue Code, Section 250

That ₱1,000-per-failure, ₱25,000-per-year structure is the base figure applied through the compromise penalty schedule in RMO No. 7-2015, which BIR examiners use in practice rather than pursuing every case through litigation. A GOCC or an entity within an LGU that separately qualifies as a micro or small taxpayer could see the Section 250 penalty itself reduced to ₱500 per failure, capped at ₱12,500 per year, under RR No. 6-2024 — though most NGAs, GOCCs, and LGU offices file under their own institutional TIN and typically won’t meet that micro/small taxpayer classification, so this reduction is the exception rather than the rule for government filers. Because QAP is filed with, not separately from, BIR Form 1601-EQ, a late QAP usually means the underlying return was also late — which brings its own surcharge and interest exposure under Sections 248 and 249 of the NIRC, on top of the Section 250 penalty for the alphalist itself.

Frequently asked questions #

Does a government agency file a separate alphalist for Government Money Payments withholding? #

No. A national government agency (NGA), government-owned or controlled corporation (GOCC), or local government unit (LGU) that withholds creditable tax on Government Money Payments (GMP) files the same Quarterly Alphalist of Payees (QAP) that every other withholding agent files. There is no GMP-specific alphalist form.

What is QAP and which return does it attach to? #

QAP (Quarterly Alphalist of Payees) is the DAT file listing every payee a withholding agent withheld creditable tax from during the quarter. It attaches to BIR Form 1601-EQ (expanded/creditable withholding) under Revenue Regulations No. 11-2018, and is due the same date as that return.

Does filing QAP replace issuing BIR Form 2307 to a supplier? #

No. QAP is the withholding agent’s own quarterly summary filed with the BIR. BIR Form 2307 is a separate, per-transaction certificate the same withholding agent issues directly to each supplier as proof of the tax withheld. A GMP withholding agent does both for the same payment, not one instead of the other.

What penalty applies if a GMP withholding agent files QAP late? #

A late or missing QAP is treated as a failure to file a required information return under Section 250 of the NIRC — a ₱1,000 penalty per failure, capped at ₱25,000 per calendar year — plus any applicable compromise penalty under RMO No. 7-2015. A qualifying micro or small government-related entity may have the Section 250 penalty itself reduced to ₱500 per failure, capped at ₱12,500 per year, under RR No. 6-2024.

Do GOCCs and LGUs use the same QAP layout as private companies? #

Yes. The QAP DAT file layout, TIN formatting, and ATC-code fields are the same regardless of whether the withholding agent is a private company, a GOCC, or an LGU. What differs for GMP withholding agents is which ATC codes apply to their payments — the government-specific goods and services codes — not the file structure itself.

Summary #

GMP withholding agents don’t need to hunt for a special government alphalist — QAP under Revenue Regulations No. 11-2018 already covers them, the same way it covers every other creditable-withholding filer. What makes GMP distinct is the rate and ATC code applied to each payment, not the form used to report it. A treasurer’s office, procurement unit, or disbursing officer should treat QAP and BIR Form 2307 as two required outputs from the same payment data, reconciled against each other and against BIR Form 1601-EQ before either is filed. For the government-specific rates and certificate rules behind these numbers, see BIR Form 2307 for Government Money Payments; for the general QAP due-date calendar, see QAP Filing Deadlines; and for the DAT conversion mechanics themselves, see How to Convert Excel to BIR DAT File for QAP.