Do You Still File RELIEF SLSP for the Quarter You Cancel Your VAT Registration?

Yes — you still file RELIEF SLSP for the quarter your VAT registration is cancelled, because the obligation attaches to every day you remained VAT-registered, not to the calendar quarter as a whole. VAT registration doesn’t end the moment you file BIR Form 1905; it ends on a specific effective date the BIR sets under NIRC Section 236(F). Any VAT-registered sales and purchases before that date still belong on a RELIEF SLSP.

Why doesn’t RELIEF SLSP stop the day you apply to cancel VAT registration? #

Filing BIR Form 1905 to cancel VAT registration starts an RDO process — it does not instantly end your VAT status or the RELIEF SLSP obligation that comes with it. RELIEF SLSP is required of VAT-registered taxpayers under Revenue Regulations (RR) No. 16-2005, as amended by RR No. 1-2012, which extended the quarterly Summary List of Sales and Purchases requirement to all VAT-registered persons regardless of transaction volume. As long as you remain VAT-registered for any part of a quarter, that quarter’s sales and purchases while VAT-registered still belong on a RELIEF SLSP.

When does VAT registration cancellation actually take effect? #

Cancellation of VAT registration takes effect on the first day of the month following the RDO’s approval of your BIR Form 1905 update, not on the date you submitted the application. NIRC Section 236(F) sets out the general cancellation mechanism:

“The registration of any person who ceases to be liable to a tax type shall be cancelled upon filing with the Revenue District Office where he is registered, an application for registration information update in a form prescribed therefor.”

Filing starts the process, but the BIR still has to verify eligibility — confirming, for example, that a mandatorily VAT-registered taxpayer’s gross sales stayed at or below the ₱3,000,000 threshold for three consecutive years, per the framework in RR No. 8-2018 (see How to Cancel Your VAT Registration and Shift Back to Non-VAT with the BIR for that eligibility test). Until the effective date the RDO sets, you remain VAT-registered, and every RELIEF SLSP obligation that comes with that status keeps running.

What exactly goes on the transition quarter’s RELIEF SLSP? #

The transition quarter’s RELIEF SLSP covers every VAT-registered sale and purchase from the start of that quarter through the effective date of cancellation — not the whole quarter, and not zero. This includes one item easy to overlook: the deemed sale of remaining inventory.

Under NIRC Section 106(B), retirement from or cessation of VAT-registered status is treated as a deemed sale of goods and properties on hand, meaning output VAT is due on the fair market value of unsold inventory as of the cancellation date, even though nothing was actually sold to a customer. That deemed-sale amount is VAT-registered activity that occurred before cancellation took effect, so it belongs on the final RELIEF SLSP (typically under the sales listing) alongside the final BIR Form 2550Q it supports — not left off because “the business isn’t VAT anymore” by the time the return is prepared.

Practically, closing out this filing also intersects with Revenue Memorandum Circular (RMC) No. 47-2026, which streamlined the documentary requirements for closing or cancelling a BIR registration generally. That circular didn’t change the substance of what has to be filed before closure — outstanding VAT returns and their DAT attachments for the final period still have to go in — only how much paperwork that filing takes at the RDO. See How to Close or Cancel Your BIR Business Registration Under RMC No. 47-2026 for the closure procedure itself.

Does cancelling VAT registration also end your QAP or SAWT obligations? #

No — QAP and SAWT are independent of VAT status, so cancelling VAT registration does not automatically end either one. RELIEF SLSP is a VAT-specific attachment; QAP and SAWT are not:

A retailer that shifts from VAT to the 8% income tax option or percentage tax under Section 116 can easily assume “no more BIR DAT files” once VAT registration is gone — but if it still pays a security agency, a bookkeeper, or a lessor and withholds tax on those payments, QAP keeps applying regardless of VAT status. Only RELIEF SLSP is VAT-specific and stops with the VAT registration itself.

A worked example #

Mabuhay Hardware Supply, a sole proprietorship, has stayed below the ₱3,000,000 VAT threshold for three consecutive years and applies on August 10, 2026 to cancel its VAT registration and shift to percentage tax. The RDO approves the update on August 22, 2026, and under standard BIR practice the cancellation takes effect September 1, 2026 — the first day of the month following approval.

For the third quarter (July–September 2026), Mabuhay Hardware Supply is VAT-registered for July and August but not September. Its RELIEF SLSP for Q3 2026 — filed with its final BIR Form 2550Q — covers only July 1 through August 31 sales and purchases, plus the Section 106(B) deemed sale of its remaining hardware inventory valued as of August 31. From September 1 onward, it files BIR Form 2551Q (percentage tax) instead, and RELIEF SLSP no longer applies. It continues filing QAP for the rest of the year, however, because it still withholds 1% expanded withholding tax on payments to its bookkeeping service under BIR Form 2307.

Frequently asked questions #

Do you still file RELIEF SLSP for the quarter your VAT registration is cancelled? #

Yes. RELIEF SLSP attaches to every quarter you were VAT-registered for any part of that quarter under Revenue Regulations No. 16-2005, as amended, so the transition quarter — the one containing your cancellation’s effective date — still requires a RELIEF SLSP covering all VAT-registered sales and purchases up to that date.

When does VAT registration cancellation actually take effect? #

Not on the date you file BIR Form 1905. In BIR practice, cancellation of VAT registration under NIRC Section 236(F) takes effect on the first day of the month following the RDO’s approval of the update, not the filing date itself — so you remain VAT-registered, with RELIEF SLSP still running, through the end of the month cancellation is approved.

Does cancelling VAT registration also stop your QAP or SAWT filing obligation? #

No, not automatically. QAP and SAWT attach to withholding agent and creditable-withholding-tax obligations, which are independent of VAT status. A business that shifts from VAT to percentage tax can still owe QAP if it withholds tax on payments to suppliers or professionals, and SAWT if it has creditable withholding tax to claim against its income tax return.

What happens to unsold inventory when you stop being VAT-registered? #

Under NIRC Section 106(B), retirement from or cessation of VAT-registered status is treated as a deemed sale of goods and properties on hand, so the business must account for output VAT on the fair market value of remaining inventory as of the cancellation date — and that deemed sale itself belongs on the final RELIEF SLSP for the transition quarter.

What form do you file after VAT registration is cancelled? #

From the effective date of cancellation onward, a business shifts from BIR Form 2550Q (Quarterly VAT Return) to BIR Form 2551Q (Quarterly Percentage Tax Return) under Section 116 of the NIRC, and RELIEF SLSP no longer applies since it is a VAT-specific attachment, not a percentage-tax one.

Summary #

RELIEF SLSP doesn’t end the day you file BIR Form 1905 to cancel VAT registration — it runs through the effective date of cancellation the RDO sets under NIRC Section 236(F), typically the first day of the month after approval. The transition quarter’s RELIEF SLSP has to cover every VAT-registered sale and purchase up to that date, including the Section 106(B) deemed sale of remaining inventory, before the business shifts fully to BIR Form 2551Q. QAP and SAWT are separate obligations tied to withholding activity, not VAT status, so don’t assume they end at the same time RELIEF SLSP does. For the eligibility and BIR Form 1905 mechanics behind the cancellation itself, see How to Cancel Your VAT Registration and Shift Back to Non-VAT with the BIR; for the broader closure process, see RMC No. 47-2026.