RELIEF SLSP: Do You Still Report Zero-Rated and VAT-Exempt Sales?

Yes — zero-rated and VAT-exempt sales must be reported in the RELIEF Summary List of Sales and Purchases (SLSP), not just regular taxable sales. The SLSP is not limited to VATable transactions; every sale a VAT-registered taxpayer books in the quarter goes on the schedule, classified by its Nature of Sales code (Vatable, Zero-Rated, Exempt, or subject to Final VAT) so the BIR can cross-match it against the corresponding BIR Form 2550Q.

Why zero-rated and exempt sales still belong in the SLSP #

A common misconception is that RELIEF SLSP only exists to track output VAT, so sales that generate no VAT can be skipped. That is incorrect. The Summary List of Sales (SLS) reports every sale to a regular buyer for the quarter — taxable, zero-rated, and exempt alike — because the schedule’s purpose is complete third-party verification of a taxpayer’s total sales, not just the VATable portion.

This is not a new interpretation. Revenue Regulations (RR) No. 8-2002, issued June 13, 2002, amended RR No. 7-95 to set the contents and electronic submission requirements for the quarterly Summary List of Sales and Purchases, and follow-on issuances — Revenue Memorandum Circular No. 24-2002 on the prescribed electronic format, and Revenue Memorandum Order No. 4-2003 on processing and penalties — built out the same schedule to carry a Nature of Sales classification rather than a VATable-only list. The BIR later removed even the old peso threshold that let smaller filers skip the SLSP. As captioned in BIR Revenue Regulations No. 1-2012:

“Requiring the Mandatory Submission of Quarterly Summary List of Sales and Purchases (SLSP) by All VAT Registered Taxpayer Thereby Amending Section 4.114-3 of Revenue Regulations No. 16-2005, as Amended”

That title makes the scope explicit: all VAT-registered taxpayers, not only those above a sales or purchase threshold — and the requirement carries no carve-out for zero-rated or exempt transactions. The current legal basis traces to Section 237, in relation to Section 244, of the National Internal Revenue Code, implemented through RR No. 16-2005 as amended by RR No. 1-2012 and, most recently, by the Ease of Paying Taxes (EOPT) Act (Republic Act No. 11976) and its implementing rules under RR No. 3-2024.

Do not confuse this with a “zero SLSP” filing, which is a nil-transaction return a taxpayer files when it had no sales or purchases at all that quarter. A zero-rated sale is a real, recorded transaction taxed at 0% under the VAT system — it still has to appear as a line item in the SLSP, coded correctly, even though no output VAT is collected on it.

How the Nature of Sales classification works #

Every row in the Summary List of Sales carries a Nature of Sales code that tells the BIR how that transaction was taxed, not just how much it was worth. Getting this code wrong is the single most common reason a filer’s SLSP figures fail to tie out to their BIR Form 2550Q, because each code feeds a different line on the return.

For a fuller walkthrough of why zero-rated and exempt sales are treated so differently on the input-VAT side even though both show no output VAT to the buyer, see Zero-Rated vs VAT-Exempt Sales: What’s the Difference and Why It Matters for Input VAT.

Worked example: one quarter, three sale types #

A taxpayer that mixes taxable, zero-rated, and exempt sales in the same quarter needs three separate lines in the SLSP for each buyer, not one blended figure. Lumping them together is the fastest way to produce an SLSP total that cannot be reconciled against the return.

Take a fictional VAT-registered exporter, Maayos Foods Trading, for Q2 2026:

• Domestic taxable sales: ₱1,800,000 in local distributor sales, coded Vatable, generating ₱216,000 output VAT (12%).
• Zero-rated export sales: ₱3,200,000 in goods shipped to a foreign buyer, coded Zero-Rated under NIRC Section 106(A)(2), with ₱0 output VAT but the related input VAT still claimable.
• Exempt sales: ₱450,000 in raw agricultural food products sold unprocessed, coded Exempt under NIRC Section 109, with ₱0 output VAT and no input VAT credit on the costs tied to that line.

In the SLSP, each of these appears as its own buyer-level entry with its own Nature of Sales code — the ₱1,800,000, the ₱3,200,000, and the ₱450,000 do not net against each other or collapse into a single “total sales” row. When Maayos Foods files BIR Form 2550Q for the quarter, the return’s taxable, zero-rated, and exempt sales boxes should trace directly back to these same three SLSP subtotals. A reviewer checking the DAT file against the return should be able to match each classification code to the matching line on the 2550Q without adjustment.

Why the classification code matters for 2550Q reconciliation #

A miscoded SLSP line is one of the most common triggers for a BIR mismatch letter, because the RELIEF system cross-checks a taxpayer’s reported sales against what its buyers report as purchases. If a zero-rated export sale is accidentally coded Vatable, the SLSP implies output VAT that the 2550Q never reported — an inconsistency the BIR’s matching program flags automatically.

The same risk runs the other way: coding a regular taxable sale as Exempt or Zero-Rated understates output VAT liability on paper, even if the return itself was correct, because the SLSP and the return are expected to describe the same set of transactions consistently. For the mechanics of tying SLSP totals back to the return line by line, see RELIEF SLSP vs BIR Form 2550Q: How to Reconcile Your Sales and Purchases Listing.

Because RR No. 1-2012 removed the old sales/purchase threshold and made the SLSP mandatory for every VAT-registered taxpayer, there is no small-filer exception that lets a business skip listing its zero-rated or exempt sales — the classification requirement applies at any transaction size. Background on who must file, and what does or doesn’t count toward the (now largely obsolete) threshold rules, is covered in RELIEF SLSP Who Must File? Threshold Rules Explained. For the broader mechanics of what RELIEF SLSP is and how the DAT file is structured, start with What Is RELIEF SLSP? BIR Summary List of Sales and Purchases Explained.

Summary #

Zero-rated and VAT-exempt sales are not exempt from RELIEF SLSP reporting — only from output VAT. Every VAT-registered taxpayer lists all of its sales in the SLSP, coded by Nature of Sales (Vatable, Zero-Rated, Exempt, or subject to Final VAT), a requirement that traces back through RR No. 8-2002, RMC No. 24-2002, RMO No. 4-2003, RR No. 1-2012, and now the EOPT Act’s implementing RR No. 3-2024. Coding each line correctly — and keeping the taxable, zero-rated, and exempt subtotals separate rather than blended — is what lets the SLSP tie out cleanly to BIR Form 2550Q and avoid a BIR cross-matching flag.