RELIEF SLSP vs QAP: Why the Same Purchase Can Appear on Both — and How They're Different Filings

RELIEF SLSP and the Quarterly Alphalist of Payees (QAP) are not duplicate filings, even when the exact same purchase shows up on both. RELIEF SLSP reports a transaction because it is VAT-relevant, under Revenue Regulations (RR) No. 1-2012; QAP reports it because the payment triggered withholding tax, under RR No. 11-2018. A single purchase can satisfy both triggers at once — that is correct reporting, not an error to fix.

Two filings, two legal triggers #

RELIEF SLSP and QAP exist under separate sections of BIR regulations because they answer separate legal questions: did VAT apply to this transaction, and was tax withheld from this payment? A VAT-registered withholding agent routinely answers “yes” to both questions on the same purchase, which is exactly when the transaction legitimately lands on two different BIR filings.

• RELIEF SLSP asks: was this a VAT-relevant sale or purchase for the quarter? Its purpose is cross-matching output VAT claimed by a seller against input VAT claimed by a buyer.
• QAP asks: was this payment subject to creditable expanded withholding tax (EWT) or final withholding tax (FWT)? Its purpose is confirming that tax withheld at source was actually remitted.

Because the two questions test different facts about the same transaction, “appearing on both” is the expected outcome for any purchase that is both a VAT purchase and a withholdable income payment — not evidence of double-counting.

RELIEF SLSP’s legal basis: it’s a VAT filing #

RELIEF SLSP is a VAT-reporting obligation, not a withholding obligation — its legal basis is RR No. 1-2012, which amended the Consolidated VAT Regulations (RR No. 16-2005) to make quarterly Summary List submission mandatory. It attaches to BIR Form 2550Q and reports purchases and sales regardless of whether any withholding tax applied to the same transaction.

RR No. 1-2012 was issued under Sections 244 and 245 of the National Internal Revenue Code to amend Section 4.114-3 of RR No. 16-2005. Its operative text on who must file the Summary List of Sales reads:

“All persons liable for VAT such as manufacturers, wholesalers, service-providers, among others are required to submit Summary List of Sales.”

— RR No. 1-2012, amending Section 4.114-3(a) of RR No. 16-2005

Nothing in that provision conditions the filing on withholding tax having been deducted. A VAT-registered taxpayer’s purchase from a VAT-registered supplier belongs on the Summary List of Purchases simply because VAT was charged on the transaction — whether or not that same payment was also subject to EWT.

QAP’s legal basis: it’s a withholding filing #

QAP is a withholding-tax obligation, not a VAT obligation — its legal basis is RR No. 11-2018, which governs the alphalist of payees attached to the quarterly withholding remittance returns. QAP lists every payee a withholding agent paid income to during the quarter, together with the Alphanumeric Tax Code (ATC) and tax withheld, and it attaches to BIR Form 1601-EQ (expanded withholding) or BIR Form 1601-FQ (final withholding) rather than to the VAT return.

QAP’s inclusion test is whether a payment is subject to creditable or final withholding tax under the ATC schedule, independent of the payee’s VAT registration status. A non-VAT-registered professional paid a withholdable fee belongs on QAP even though that payment never touches a VAT return at all. Conversion mechanics for building a QAP file are covered in How to Convert Excel to BIR DAT File for QAP, and common rejection causes are covered in Common QAP DAT File Errors.

Comparison: RELIEF SLSP vs QAP #

The two filings differ in legal basis, trigger, attached return, and filing frequency, even though both are submitted as DAT files through the same BIR eSubmission channel. The table below lines up the differences a withholding agent needs to track side by side.

Both DAT types pass through the same eSubmission facility; see What Is the BIR eSubmission System? for how that channel works for RELIEF, QAP, and other alphalist DAT files.

Worked example: one purchase, two correct filings #

A single contractor payment with both VAT and withholding tax shows exactly how the same ₱100,000 transaction produces one row on the Summary List of Purchases and one row on QAP, for two unrelated reasons. The names and TIN below are fictional.

A VAT-registered trading company hires Metro Builders Services, a VAT-registered contractor, for repair work during Q3 2026 (July–September):

• Gross contract price: ₱100,000.00
• Output VAT charged by the contractor (12%): ₱12,000.00
• Total invoice amount: ₱112,000.00
• Expanded withholding tax withheld by the trading company (2%, ATC WC160 for contractors): ₱2,000.00 (2% of the ₱100,000.00 gross, before VAT)
• Net amount paid to Metro Builders Services: ₱110,000.00

This one transaction correctly appears on two separate filings:

1. RELIEF Summary List of Purchases — the ₱100,000.00 taxable purchase and ₱12,000.00 input VAT are listed because the trading company bought a VAT-relevant service. Withholding tax never enters this schedule.
2. QAP — the ₱100,000.00 income payment and ₱2,000.00 tax withheld are listed under ATC WC160 because the payment was subject to EWT. VAT status of the contractor never enters this schedule.

The trading company also issues BIR Form 2307 to Metro Builders Services as the certificate of creditable tax withheld, which the contractor later uses to support its own tax credits — a separate downstream document built from the same QAP-side withholding data, not from the SLSP side.

If the company had instead bought the same service from a non-VAT-registered sole proprietor who happened to be below the EWT threshold for that income type, the transaction could appear on RELIEF SLSP only, on QAP only, on neither, or — as in this example — both, depending entirely on which two independent tests (VAT-relevance, withholding trigger) it satisfies.

Why mismatches still draw BIR attention #

Even though RELIEF SLSP and QAP are not reconciled line-for-line by rule, the BIR’s third-party matching program compares a taxpayer’s reported purchases and sales against counterparties’ own Summary Lists and alphalists of payees, and flags discrepancies through a Letter Notice (LN). An LN is a discrepancy notice, distinct from a full audit under a Letter of Authority, but it can escalate into one if the gap is not resolved.

In practice, this means a vendor that should logically appear on both filings — a VAT-registered supplier regularly paid withholdable fees — but shows up consistently on only one invites a BIR query, not because the two schedules must match row for row, but because the pattern suggests either an unreported VAT purchase or an unremitted withholding tax, not a harmless filing-mechanics difference. Keeping both schedules grounded in the same source ledger, rather than two separately reconstructed spreadsheets, is the practical way to avoid that exposure. For the broader RELIEF filing mechanics this affects, see What Is RELIEF SLSP?.

Frequently asked questions #

Is reporting a purchase on both RELIEF SLSP and QAP double reporting? #

No. RELIEF SLSP and the Quarterly Alphalist of Payees (QAP) report the same underlying transaction for two different legal reasons — the VAT on the purchase under the Summary List of Purchases rules, and the withholding tax on the payment under the alphalist of payees rules. The same purchase appearing on both is expected, not a duplicate filing.

What is the legal basis for RELIEF SLSP versus QAP? #

RELIEF SLSP’s legal basis is Revenue Regulations No. 1-2012, which amended Section 4.114-3 of Revenue Regulations No. 16-2005 (the Consolidated Value-Added Tax Regulations), making quarterly Summary List of Sales and Summary List of Purchases submission mandatory for VAT-registered taxpayers. QAP’s legal basis is Revenue Regulations No. 11-2018, which governs the alphalist of payees attached to the withholding tax remittance returns, BIR Form 1601-EQ and BIR Form 1601-FQ.

Which return does each filing attach to? #

RELIEF SLSP attaches to BIR Form 2550Q, the Quarterly VAT Return, and is due on the same 25th- or 30th-day deadline as that return. QAP attaches to BIR Form 1601-EQ (expanded withholding) or BIR Form 1601-FQ (final withholding), due on or before the last day of the month following the close of the taxable quarter.

Does a purchase have to be VAT-registered to appear on QAP, or withholdable to appear on RELIEF SLSP? #

No, and that is the core of the confusion. A purchase appears on RELIEF SLSP because it is a VAT-relevant transaction, regardless of whether withholding tax applies. A payment appears on QAP because it is subject to expanded or final withholding tax, regardless of whether the supplier is VAT-registered. A non-VAT supplier paid a withholdable professional fee shows up on QAP but not on RELIEF SLSP; a VAT-registered supplier paid for a transaction with no withholding trigger shows up on RELIEF SLSP but not on QAP.

Does the BIR check for mismatches between RELIEF SLSP and QAP during an audit? #

Yes, informally. The BIR’s third-party matching program cross-references a taxpayer’s purchases and sales against counterparties’ Summary Lists and alphalists of payees, and discrepancies are communicated through a Letter Notice. A vendor that appears consistently on one list but never on the other for payments that should trigger both obligations is the kind of pattern that draws a Letter Notice query, even though the two filings are not reconciled line-for-line by rule.

Summary #

RELIEF SLSP and QAP are two independent filings built on two independent legal triggers — VAT-relevance under RR No. 1-2012 versus withholding tax under RR No. 11-2018 — not two versions of the same report. A purchase that is both a VAT transaction and a withholdable payment, like the fictional Metro Builders Services example above, correctly appears on the Summary List of Purchases attached to BIR Form 2550Q and on QAP attached to BIR Form 1601-EQ, for two separate reasons. Treat “it’s on both lists” as confirmation the transaction was classified correctly, not as a duplicate to clean up — and keep both schedules sourced from the same underlying ledger so a real mismatch stands out before the BIR’s own matching program finds it first.