Can You Skip BIR Form 1601-EQ and QAP in a Quarter With Zero Withholding Tax?

Generally, no — you cannot simply skip BIR Form 1601-EQ for a quarter with zero withholding tax, but the QAP attachment is a different story. As a registered withholding agent, you are expected to file BIR Form 1601-EQ as a “no payment” return showing zero, because the filing obligation runs with your BIR registration, not with whether tax was actually withheld. The Quarterly Alphabetical List of Payees (QAP), by contrast, is a list of specific payees and amounts — if there were none, there is nothing to list, so there is no payee-data file to generate or submit for that quarter.

Why the return and the attachment are not the same obligation #

BIR Form 1601-EQ is a tax return; the QAP is a reporting attachment listing payees. A return declares a filing period’s activity to the BIR and must exist for every period a taxpayer is registered to file, even when the declared amount is zero. An attachment like the QAP, on the other hand, only has content when there is something to list — specific payees, their TINs, and the amounts withheld from each. Treating the two as one obligation is the most common source of confusion behind “can I skip it” questions.

This distinction mirrors a related, better-documented rule for BIR Form 2307: the certificate is generated per payee transaction, so a withholding agent with no subject-to-CWT payment in a period has no BIR Form 2307 to issue — there is simply nothing to produce — while separate withholding returns can still be due for that same nil period regardless. The QAP follows the same logic as the certificate, not as the return, because both are built from actual payee transactions rather than existing independently of them.

The general BIR principle: registration drives the filing obligation #

Once you are registered with the BIR for a given return and tax type, you are expected to file that return for every applicable period until the BIR formally updates your registration — regardless of whether there was any activity. This “no payment return” principle is not unique to withholding tax; it is the same logic behind filing a zero percentage tax return, a zero VAT return, or a zero income tax return for a period with no transactions. The return exists to confirm, on BIR’s own records, that the period was genuinely inactive rather than simply unreported.

For expanded withholding tax specifically, this plays out even at the monthly level before it reaches the quarter. P&A Grant Thornton’s tax alert on Revenue Regulations (RR) No. 11-2018 — the regulation that introduced the current BIR Forms 0619-E, 0619-F, 1601-EQ, and 1601-FQ filing scheme — notes plainly that “withholding agents with zero remittance are still required to file BIR Form Nos. 0619E and 0619F for the month.” Since BIR Form 1601-EQ is the quarterly return that consolidates those same monthly remittances for expanded withholding tax, the same logic carries through: a withholding agent registered to file 1601-EQ remains obligated to file it for the quarter, declaring zero, unless the BIR has specifically removed that tax type from the taxpayer’s registration (BIR Form 1905 update).

Why the QAP doesn’t work the same way #

The QAP is defined by its contents — payee-level data — not by the filing period itself, so a quarter with no payees has no QAP data to build. RR No. 11-2018 describes what the QAP must contain when it is filed. As quoted in P&A Grant Thornton’s tax alert on the regulation:

“Quarterly Alphabetical List of Payees (QAP) containing the following information shall be filed on a quarterly basis: Name of Income Payees, Taxpayer Identification Number (TIN), Amount of income payment segregated per month with a total for the quarter, Income payment subjected to withholding tax, Income payment exempt from withholding tax, Amount of taxes withheld.”

— RR No. 11-2018, as quoted in P&A Grant Thornton’s tax alert “Updated Rules on the Filing and Payment of Withholding Tax”

Every one of those six required fields — payee name, TIN, monthly amounts, taxable/exempt split, tax withheld — only exists when there is an actual payee to report. If no payment subject to (or exempt from) expanded withholding tax was made during the quarter, there is no payee row to populate any of those fields with, which is the practical reason the QAP is treated differently from the return it attaches to. The BIR’s own Alphalist Data Entry and Validation Module (the tool used to build the DAT file submitted through esubmission@bir.gov.ph) is built around generating files from payee records — it was not designed to produce a meaningful file with zero records, which is a different situation from a return form that always has a zero line to declare.

In practice, the safer approach when you have genuinely zero payees for the quarter is to still note “no transactions / no payees to report this quarter” in your eSubmission email or cover note to your Revenue District Office, rather than going silent — that keeps a record that the absence was deliberate and known, instead of leaving the BIR to wonder whether an attachment is simply missing. For the mechanics of actually building a QAP DAT file from your records, see How to Convert an Excel File Into a BIR QAP DAT File; for the validation errors that show up most often once there is real payee data, see Common BIR QAP DAT File Errors and How to Fix Them.

What filing late or not at all can still cost you #

Even when the correct tax due is genuinely zero, skipping or delaying a required return is not risk-free — the surcharge and interest compute to nothing, but a compromise penalty for late or non-filing can still apply, and an unfiled return leaves an open case on BIR’s records. The 25% surcharge and the deficiency interest the Tax Code imposes on late filing are both calculated as a function of the unpaid tax due; when that amount is truly zero, both compute to zero. That is not the same as there being no consequence at all. The BIR’s compromise penalty schedule under RMO No. 7-2015 sets fixed amounts — historically starting at a minimum of ₱1,000 per return per violation — for late filing and for non-submission of required returns and attachments, independent of whether any tax was actually due.

The QAP carries its own, separate exposure once there are actual payees: under the same compromise penalty framework, late or non-submission of the alphalist is penalized per failure (subject to an annual cap per category), and non-submission repeated over two consecutive years is treated as willful and not eligible for compromise at all. None of that applies to a quarter with zero payees, because there is no QAP obligation to fail at in the first place — but it is the reason to actually build and check your QAP carefully in the quarters when you do have payees, rather than treating the “zero quarter means skip it” habit as a general rule.

Not filing BIR Form 1601-EQ at all for a zero quarter — rather than filing it showing zero — also risks creating an “open case” against your registration, which the BIR’s system flags for a required return with no corresponding filing on record. Resolving an open case later, even for a period where no tax was ever due, is generally more work than filing the no-payment return on time would have been.

Related reading #

For the mechanics of the quarterly return itself — deadlines, how the monthly 0619-E remittances roll up into it, and what a completed 1601-EQ looks like — see BIR Form 1601-EQ: How to File the Quarterly Expanded Withholding Tax Return. If your “zero quarter” question is really about which rate schedule applies once you do have payees — because you are both an ordinary withholding agent and a classified Top Withholding Agent — see Filing BIR Form 1601-EQ When You’re Both a Regular Withholding Agent and a Top Withholding Agent.

Frequently asked questions #

Do I still file BIR Form 1601-EQ if I withheld nothing the whole quarter? #

Generally yes. A taxpayer registered as a withholding agent for expanded withholding tax remains obligated to file BIR Form 1601-EQ for every quarter covered by that registration, reporting zero, unless the BIR has specifically updated that registration to remove the withholding tax type. Filing a no-payment return is the standard way BIR systems confirm a quarter had no activity, rather than leaving an open case on record.

Does the QAP need a DAT file attached if there were no payees that quarter? #

No. The Quarterly Alphabetical List of Payees (QAP) is a list of specific payees, their TINs, and amounts withheld from them. If a withholding agent made no payment subject to withholding during the quarter, there is no payee row to generate, so there is no meaningful QAP file to format and submit — the obligation to report sits on the return (BIR Form 1601-EQ), not on an empty attachment.

Is BIR Form 1601-EQ with zero withholding the same as a ’no payment return'? #

Yes. A return showing zero tax withheld and zero tax due is what the BIR and tax practitioners refer to as a no-payment return. It still has to be filed by the deadline through eBIRForms or eFPS like any other 1601-EQ; the only difference is that no amount is remitted alongside it.

What happens if I just don’t file BIR Form 1601-EQ for a zero quarter? #

Failing to file any return — including a no-payment one — for a period a taxpayer is registered to file for typically creates an open case on the BIR’s records and exposes the taxpayer to a compromise penalty for late or non-filing under the BIR’s compromise penalty schedule, separate from any surcharge or interest (which computes to nothing when the actual tax due is genuinely zero). Filing on time, even at zero, avoids that exposure.

If I’m not a Top Withholding Agent and simply had no withholdable transactions, does the same rule apply? #

Yes, the filing obligation tracks your BIR registration for the expanded withholding tax type, not your Top Withholding Agent status. An ordinary withholding agent registered for BIR Form 1601-EQ who happens to have no rent, professional fee, commission, or other withholdable payment in a given quarter still files a zero 1601-EQ for that quarter on the same logic as a Top Withholding Agent would.

Summary #

A zero-withholding quarter does not let a registered withholding agent skip BIR Form 1601-EQ — file it as a no-payment return, declaring zero, by the usual quarterly deadline, because the obligation runs with your registration rather than with actual activity. The QAP is different: it is a list of payees, and a quarter with no payees has no payee data to format into a DAT file, so there is no meaningful QAP submission to make. Treat the return and the attachment as two separate obligations with two separate triggers, note “no transactions” to your RDO when the QAP genuinely has nothing to carry, and save the careful DAT-file work for the quarters when you actually have payees to report — see How to Convert an Excel File Into a BIR QAP DAT File and Common BIR QAP DAT File Errors and How to Fix Them for that part of the process.