QAP vs Annual Alphalist (1604-E): What's the Difference and When Is Each Required?

QAP and the BIR Form 1604-E alphalist both report a withholding agent’s expanded withholding tax payees, but on different clocks: QAP is filed every quarter with BIR Form 1601-EQ or 1601-FQ, while the BIR Form 1604-E alphalist is filed once a year, after year-end, consolidating all four quarters into a single reconciliation return due March 1. Filing one does not excuse the other — they are separate, cumulative obligations built from the same underlying payee records.

What exactly is QAP, and what does it report? #

QAP (Quarterly Alphalist of Payees) is the withholding agent’s electronic listing of every payee it subjected to expanded or final withholding tax during one calendar quarter, submitted as a DAT file attached to BIR Form 1601-EQ (expanded/creditable withholding) or BIR Form 1601-FQ (final withholding). It is required under Revenue Regulations (RR) No. 11-2018, which amended Section 2.58 of RR No. 2-98 governing returns and payments of taxes withheld.

The regulation’s own language describes what a QAP row must contain:

“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

Because QAP tracks only one quarter’s payments, a withholding agent files a fresh QAP alongside every 1601-EQ or 1601-FQ — four times in a normal calendar year. For the deadline calendar itself, see QAP Filing Deadlines; for what belongs in each row, see What Is QAP?.

What exactly is the BIR Form 1604-E alphalist, and what does it report? #

BIR Form 1604-E is the Annual Information Return of Creditable Income Taxes Withheld (Expanded), and its attached alphalist consolidates every payee subjected to expanded withholding tax across the entire calendar year — not just one quarter. It is the year-end counterpart to the four QAP filings already submitted, not a substitute for any of them.

BIR Form 1604-E’s alphalist splits into two schedules:

• Schedule 3 — payees subject to expanded withholding tax whose income is reported under BIR Form 2307
• Schedule 4 — payees whose income payments are exempt from withholding but still subject to income tax, reported under BIR Form 2304

Under RR No. 11-2018, BIR Form 1604-E and its alphalist are due on or before March 1 of the year following the taxable year covered — a full two months after the calendar closes, giving withholding agents time to reconcile a year’s worth of quarterly QAP data into one annual filing. This March 1 deadline and the Schedule 3/4 split are covered in more depth, alongside the related 1604-C and 1604-F annual returns, in BIR Annual Alphalist (1604-C, 1604-E, 1604-F).

QAP vs BIR Form 1604-E alphalist: side by side #

The clearest way to see the difference is to compare frequency, the return each attaches to, and what each one actually consolidates. Both draw on the same underlying payee, ATC, and withholding data — they just report it at different intervals.

Worked example: four quarters of QAP reconciling into one 1604-E #

A single withholding agent’s calendar year shows how the four quarterly QAP filings roll up into one annual BIR Form 1604-E alphalist. All names, TINs, and amounts below are fictional, used only to illustrate the reconciliation.

Suppose Coral Business Solutions Inc. withholds expanded withholding tax from one recurring supplier, Peak IT Solutions Inc. (fictional TIN 789-012-345-000), under ATC WC010, throughout 2026:

By March 1, 2027, Coral Business Solutions Inc. files BIR Form 1604-E with a Schedule 3 alphalist showing Peak IT Solutions Inc. once, with the full-year totals: ₱360,000 in income and ₱18,000 in tax withheld — the sum of the four QAP filings already submitted during 2026. If any quarter’s QAP had recorded a different amount for the same payee, or had omitted the payee entirely, the year-end 1604-E total would not tie out, signaling a reconciliation error to fix before filing rather than after.

BIR Online Tools’ QAP module builds the quarterly DAT file from the same payee and ATC records used to prepare BIR Form 2307 certificates throughout the year, and the Alphalist EWT module consolidates those same records into the Schedule 3/4 alphalist that BIR Form 1604-E requires — so the annual filing reuses the data entered quarter by quarter instead of starting from a blank sheet in the following February.

Frequently asked questions #

What is the main difference between QAP and the BIR Form 1604-E alphalist? #

QAP (Quarterly Alphalist of Payees) is filed four times a year, once per quarter, as an attachment to BIR Form 1601-EQ or 1601-FQ. The BIR Form 1604-E alphalist is filed once a year, after calendar year-end, and consolidates every payee the withholding agent subjected to expanded withholding tax across all four quarters.

Does filing 1604-E replace the four quarterly QAP filings? #

No. BIR Form 1604-E and its annual alphalist are a year-end reconciliation return, filed in addition to the four quarterly QAP attachments already submitted with Form 1601-EQ or 1601-FQ during the year. Filing 1604-E does not excuse a withholding agent from any quarter’s QAP, and a completed QAP filing does not excuse the annual 1604-E.

When is BIR Form 1604-E and its alphalist due? #

BIR Form 1604-E, the Annual Information Return of Creditable Income Taxes Withheld (Expanded), together with its Alphalist of Payees, is due on or before March 1 of the year following the calendar year it covers.

Do the same payees appear on both QAP and the 1604-E alphalist? #

Yes. Every payee reported on a quarter’s QAP should reappear on the year-end 1604-E alphalist, because 1604-E consolidates the full year of expanded withholding activity that the four QAP filings already reported quarter by quarter.

What happens if the totals on QAP and 1604-E don’t match? #

A mismatch between the four quarters’ QAP totals and the year-end 1604-E alphalist signals a reconciliation error — a payee dropped from one filing, an amount recorded in the wrong quarter, or a payee added late in the year. The BIR’s Alphalist Data Entry and Validation Module can flag structural DAT errors, but matching QAP-to-1604-E totals is the withholding agent’s own reconciliation responsibility before filing.

Summary #

QAP and the BIR Form 1604-E alphalist both track expanded withholding tax payees under RR No. 11-2018, but on different clocks and for different purposes: QAP is a quarterly attachment to BIR Form 1601-EQ or 1601-FQ, due the last day of the month after each quarter, while the BIR Form 1604-E alphalist is a once-a-year reconciliation return due March 1, consolidating all four quarters’ payees into Schedule 3 and Schedule 4. Neither substitutes for the other — a withholding agent that files a clean QAP every quarter still owes the annual 1604-E, and the two should reconcile to the same totals for every shared payee. For the quarterly deadline calendar, see QAP Filing Deadlines; for the full detail on 1604-C, 1604-E, and 1604-F together, see BIR Annual Alphalist (1604-C, 1604-E, 1604-F); for what a QAP row itself contains, see What Is QAP?.