Do You Report Consigned Goods in Your RELIEF SLSP? Consignor vs Consignee Treatment

No — sending goods out on consignment is not, by itself, a RELIEF SLSP entry. The RELIEF Summary List of Sales/Purchases (SLSP) only captures completed, invoiced VAT transactions, and a consignment shipment isn’t one until either the consignee actually sells the goods to an end buyer, or the BIR’s 60-day deemed-sale rule under NIRC Section 106(B) forces the consignor to recognize the sale anyway. Get the timing wrong and you either under-report real sales or invent a transaction that never happened.

This is a narrower, mechanics-focused question than Is a Consignment Sale Subject to VAT? The 60-Day BIR Deemed-Sale Rule, which explains whether and when consigned goods become VATable in the first place. This post assumes that VAT question is settled and answers a different one: once a sale (actual or deemed) has occurred, which party — consignor or consignee — keys it into their RELIEF SLSP DAT file, and when. For the broader filing obligation this sits inside, see What Is RELIEF SLSP?

Why doesn’t shipping goods on consignment trigger a RELIEF SLSP entry? #

RELIEF SLSP rows are built from actual VAT invoices and official receipts tied to a completed sale or purchase — not from a physical transfer of inventory with no sale document behind it. The Summary List of Sales and Summary List of Purchases exist to support the BIR’s third-party cross-matching program: a seller’s reported sale on its Summary List of Sales gets checked against the same transaction on the buyer’s Summary List of Purchases. That matching only works because each row traces back to an invoice or receipt number, amount, and VAT-registered counterparty TIN.

When a consignor ships goods to a consignee under a consignment arrangement, no VAT invoice is issued at the point of shipment — title to the goods typically hasn’t transferred, and the consignee is holding the goods to sell on the consignor’s behalf, not buying them outright. Without an invoice, there’s nothing yet for a Summary List of Sales row to be built from. Recording the shipment as a sale on that date would put a transaction into the DAT file that doesn’t correspond to any invoice a counterparty could match against — creating exactly the kind of RELIEF mismatch that draws a BIR Letter Notice, covered in Why Did I Get a RELIEF SLSP Mismatch Letter Notice?.

So when does a consigned-goods transaction actually enter the RELIEF SLSP? #

Two triggers put a consignment transaction into the consignor’s RELIEF SLSP: an actual sale by the consignee to an end buyer, or the 60-day deemed-sale rule if the goods sit unsold that long. Either event produces the invoice a Summary List of Sales row needs — the difference is who the buyer is and what date gets used.

• Actual sale within 60 days. When the consignee sells consigned goods to an end customer, the consignor issues (or authorizes the consignee to issue, depending on the consignment agreement) a sales invoice for that portion sold. That invoice’s date and amount is what goes into the consignor’s Summary List of Sales for the quarter the sale happened in — not the quarter the goods were originally shipped.
• No sale, no return, within 60 days — the deemed sale. Section 106(B) of the National Internal Revenue Code (NIRC) treats consignment of goods as a transaction deemed sold for VAT purposes once 60 days pass from the consignment date without an actual sale. Section 4.106-7 of Revenue Regulations (RR) No. 16-2005, the BIR’s consolidated VAT regulations implementing that provision, states it this way:

Consignment of goods as deemed sold if actual sale is not made within 60 days following the date such goods were consigned.

When the 60th day passes with goods still unsold and not returned, the consignor recognizes a deemed sale, issues the corresponding invoice for VAT purposes on that remaining value, and reports it in the Summary List of Sales for the quarter the 60th day falls in — even though no paying customer exists. Goods the consignee actually returns within the 60-day window are not deemed sold and generate no RELIEF entry at all. The full mechanics of this timing — including what happens if the goods are returned after day 60 — are covered in Is a Consignment Sale Subject to VAT?; this post only concerns where each outcome lands in the DAT file.

Consignor vs. consignee: who reports what, and where #

The consignor and the consignee are reporting two different transactions, not the same one twice — the consignor’s Summary List of Sales entry is the sale or deemed sale of the goods themselves, while the consignee’s entries are its own purchase from the consignor and its own resale to the end customer.

A consignee that resells consigned goods to its own retail customers also has its own separate VAT obligation on that resale, with its own invoice and its own Summary List of Sales row — that transaction is independent of, and does not substitute for, the consignor’s entry for the original consignor-to-consignee sale.

Worked example: a furniture consignor and a mall consignee #

A furniture consignor shipping ₱200,000 of stock to a mall consignee ends up with two different RELIEF outcomes on the same shipment, split by the 60-day line — the sold portion enters at the actual sale date, and the unsold portion enters at day 60.

Bayani Furniture Co., a VAT-registered manufacturer, consigns ₱200,000 worth of dining chairs to a partner showroom inside a mall on August 1, 2026, under an agreement letting the showroom return anything unsold.

Bayani’s Summary List of Sales for the relevant quarter(s) ends up reflecting the full ₱200,000 — ₱150,000 from genuine sales invoices dated as each sale happened, and ₱50,000 from a single deemed-sale invoice dated at day 60. Nothing about the August 1 shipment itself ever appears as a standalone RELIEF row. On the showroom’s side, it reports its own ₱200,000 purchase from Bayani in its Summary List of Purchases (once invoiced, split the same way across actual and deemed sale dates) and separately reports its own resale of those chairs to its retail customers in its own Summary List of Sales.

Summary #

Consigning goods to another party doesn’t put anything into your RELIEF SLSP on the shipment date — the DAT file only picks up an invoiced transaction, and a consignment transfer alone isn’t one. The consignor’s Summary List of Sales entry comes later, triggered either by an actual sale the consignee makes to an end buyer or by the 60-day deemed-sale rule under NIRC Section 106(B) and RR No. 16-2005 Section 4.106-7 if the goods sit unsold past day 60. The consignee, meanwhile, reports its own purchase from the consignor and its own separate resale — two different Summary List entries tied to two different invoices, neither of which substitutes for the consignor’s. For the underlying VAT timing rules behind the 60-day trigger, see Is a Consignment Sale Subject to VAT? The 60-Day BIR Deemed-Sale Rule; for how import purchases get their own separate RELIEF treatment by contrast, see Do You Report Import Purchases in Your RELIEF SLSP?; for the filing obligation this all sits inside, see What Is RELIEF SLSP?