How to Report Consignment Sales in Your RELIEF SLSP DAT File

Shipping goods to a consignee for them to sell on your behalf is not, on its own, a RELIEF SLSP transaction — it only becomes one once the consignee actually sells the goods to a buyer, or 60 days pass without a sale, whichever happens first. Treating the shipment date as the sale date is the most common consignment mistake in RELIEF SLSP, and it either overstates sales in the shipment quarter or understates them if the 60-day deemed-sale deadline is missed entirely.

This guide covers the RELIEF reporting mechanics for consignment. For the underlying VAT substantive rule the deemed-sale deadline comes from, see Consignment Sales and the VAT 60-Day Deemed-Sale Rule; for RELIEF SLSP basics, see RELIEF SLSP: Who Must File and the Threshold That Triggers It.

When does a consignment shipment first become reportable? #

A consignment shipment is reportable in RELIEF SLSP the moment an actual sale happens — the consignee finds a buyer and sells the goods — because that’s the point title transfers and output VAT accrues, the same trigger as any ordinary sale. Until that happens, the goods sitting with the consignee are still the consignor’s inventory on the consignor’s own books, and inventory movement between locations isn’t a VAT event.

What makes consignment different from an ordinary sale is the second trigger that exists specifically to stop consignors from indefinitely parking unsold inventory outside the VAT system. NIRC Section 106(B) states the deeming rule directly, already verified and applied elsewhere on this site:

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

That means a consignor can end up owing output VAT, and must file a RELIEF SLSP entry, on inventory that’s still physically sitting unsold on the consignee’s shelf — simply because 60 days have passed.

How do the two triggers play out across a quarter boundary? #

A single consignment batch can generate a RELIEF SLSP entry in one quarter from an actual partial sale, and a second, deemed-sale entry in a later quarter for whatever remains unsold once 60 days pass — and tracking both requires the consignor to monitor the consignment date, not just wait for the consignee’s sales reports.

A consignor relying only on the consignee’s own sales reports can miss the deemed-sale trigger entirely if the consignee is slow to sell and never formally reports the shortfall — the 60-day clock runs from the consignment date regardless of whether the consignee ever communicates a status update.

Worked example: a gift-shop consignment spanning two quarters #

Manila Artisan Crafts Inc. consigns ₱150,000 worth of handwoven baskets to Island Gift Gallery on March 5. By April 20 (46 days in), the gallery has sold ₱90,000 worth to walk-in customers; the remaining ₱60,000 worth is still unsold when the 60-day deadline falls on May 4.

Both entries land in the same RELIEF SLSP quarter here because both triggers happened within Q2, but had the consignment shipped on February 20 instead, the 60-day deadline would fall in April and still land in Q2 — while a March-shipped batch with slow sales could straddle Q1 and Q2 depending on exactly when day 60 falls. Manila Artisan Crafts reports the full ₱150,000 across the two entries, with output VAT computed on each portion as it becomes reportable, never on the original shipment itself.

Frequently asked questions #

Does shipping goods to a consignee count as a sale in RELIEF SLSP? #

No. Physically transferring goods to a consignee for sale on your behalf is not, by itself, a sale for VAT purposes — there is no RELIEF SLSP entry to make at the point of shipment, because title to the goods has not transferred and no output VAT has accrued yet.

When does a consignment sale actually get reported? #

In the quarter the consignee actually sells the goods to a third-party buyer, or the quarter in which 60 days have passed since the goods were consigned without an actual sale — whichever comes first. NIRC Section 106(B) deems unsold consigned goods a sale once that 60-day window closes, which forces a RELIEF SLSP entry even without a real transaction.

Who appears as the buyer on the consignor’s RELIEF SLSP entry — the consignee or the end customer? #

The consignee, in most consignment arrangements, since the legal and invoicing relationship for VAT purposes runs from the consignor to the consignee rather than to the consignee’s own retail customers, unless the consignment agreement and the parties’ actual invoicing practice establish a different flow of documents.

What happens if the consignee returns unsold goods before the 60-day deadline? #

No sale is ever deemed to have occurred on the returned portion, and no RELIEF SLSP entry is needed for it — the 60-day deemed-sale rule only applies to goods still unsold and still in the consignee’s possession when the deadline passes, not to goods physically returned to the consignor beforehand.

Does the 60-day rule override an actual sale that happens later than 60 days? #

No, the 60-day rule is a deeming provision that triggers reporting if no real sale happens by then — it doesn’t erase or duplicate reporting for an actual sale. If the deemed-sale entry was already made at day 60 and the consignee later actually sells the same goods, the consignor doesn’t report the same goods as sold twice.

Summary #

Consignment inventory stays off your RELIEF SLSP until an actual sale happens or the NIRC Section 106(B) 60-day deemed-sale deadline passes, whichever comes first — track the consignment date for every batch, not just the consignee’s sales reports, so the deemed-sale trigger doesn’t slip past unreported.