What TIN do I put on BIR Form 2307 if the payee doesn't have one?

If a payee genuinely cannot provide a TIN, withholding agents commonly report the payment using a placeholder such as 222-222-222-000, a convention many accounting practitioners use for unidentified or unregistered payees, while still withholding and remitting the tax due — though the payor should still make a reasonable effort to obtain the payee's actual TIN first.

Can I still deduct the expense if my supplier isn't BIR-registered?

Deductibility of the expense and the withholding obligation are separate questions. Properly withholding and remitting tax on the payment, and keeping adequate documentation of the transaction, supports the expense's deductibility even when the payee's own registration status is incomplete — but the payor still needs sufficient evidence of the transaction under the BIR's substantiation rules.

Should I just avoid paying unregistered suppliers to sidestep this problem?

That's a business decision, but avoiding the transaction doesn't change the underlying rule — many small suppliers and informal freelancers in the Philippines aren't BIR-registered, and a payor engaging with them still has to meet its own withholding obligations rather than treating the supplier's registration gap as a reason to skip withholding.

Does this apply to individual freelancers the same way it applies to registered businesses?

Yes. The type of payment (professional fee, contractor fee, rent, commission, or similar) determines whether withholding applies and at what rate, regardless of whether the individual receiving payment is a registered self-employed taxpayer, an informal freelancer, or has no BIR registration at all.

What to Do When You Must Withhold Tax From a Supplier With No TIN or BIR Registration

Q: Do I still need to withhold tax if my supplier has no TIN?

Yes. A withholding agent's obligation to deduct and remit creditable withholding tax is based on the nature of the payment and the payor's own status as a withholding agent, not on whether the payee has a TIN or BIR registration. Lacking a TIN doesn't exempt a payee from being subject to withholding.

A withholding agent’s duty to withhold and remit creditable tax does not depend on whether the payee has a TIN or a BIR Certificate of Registration — it depends on the nature of the payment and the payor’s own status as a withholding agent. This is a common point of confusion for small businesses paying freelancers, informal suppliers, or contractors who have never registered with the BIR: the payor still has to withhold, even though the payee hasn’t done their part.

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Why the payee’s registration status doesn’t excuse withholding #

Revenue Regulations No. 2-98 constitutes certain payors — corporations, top withholding agents, and individuals meeting specific thresholds — as withholding agents with respect to categories of payments, and that designation attaches to the payor, not the payee. Section 2.57.3 of RR No. 2-98 defines who is required to deduct and withhold in terms that describe the payor, not the payee:

“(A) In general, any juridical person, whether or not engaged in trade or business; (B) An individual, with respect to payments made in connection with his trade or business.”

Nothing in that definition conditions the payor’s obligation on the payee’s own TIN or registration status. The obligation to deduct and remit tax on a professional fee, contractor payment, rent, or similar covered payment exists because of what the payment is and who is making it, independent of whether the recipient has bothered to register with the BIR or secure a TIN. A payee’s failure to register is the payee’s own compliance problem — it doesn’t transfer to, or excuse, the payor’s separate withholding obligation.

What to actually do at the time of payment #

Ask for the payee’s TIN and, if applicable, their Certificate of Registration before finalizing payment — many informal suppliers do have a TIN even without a formal business registration, since individuals commonly secure a TIN for employment or other purposes.
Withhold the correct rate for the type of payment, following the same rules that would apply to a fully registered payee — see the ATC codes guide for how to identify the correct rate and code for a given payment type.
Remit the withheld tax to the BIR through the applicable withholding tax return (BIR Form 0619-E monthly, BIR Form 1601-EQ quarterly) exactly as you would for any other payee.
Issue BIR Form 2307 to the payee reflecting the payment and tax withheld, using a placeholder TIN such as 222-222-222-000 only if the payee genuinely cannot provide one after being asked — not as a default shortcut.
Keep documentation of the transaction — invoices, delivery records, proof of payment — since substantiating that the payment actually occurred and was for a legitimate business purpose supports both the withholding filing and the expense’s deductibility.

What this doesn’t solve #

Withholding tax correctly from an unregistered payee addresses the payor’s own compliance obligation, but it doesn’t fix the payee’s separate registration gap, and it doesn’t automatically guarantee the expense is deductible if other documentation is missing. A payor should still request whatever receipts or invoices the payee can provide, since the BIR’s substantiation requirements for deducting a business expense are a distinct question from the withholding obligation covered in this post — see What Happens If You Have No Receipts to Prove Your Business Expenses? for how the BIR’s best-evidence-obtainable rule applies when supporting documents from an informal supplier are incomplete.

A common scenario: paying an unregistered freelancer #

A small business hires a freelance graphic designer for a one-off project and pays ₱30,000, only to learn the designer has never registered with the BIR and has no TIN. If the payment qualifies as a professional fee subject to expanded withholding tax, the business still withholds at the applicable rate — typically 5% for an individual payee whose cumulative gross receipts from the payor don’t exceed ₱3,000,000 for the year — remits ₱1,500 to the BIR, and issues a BIR Form 2307 using a placeholder TIN if the designer genuinely has none. The business has met its own obligation regardless of the designer’s registration status; the designer, separately, remains responsible for registering with the BIR and reporting their own income.

Summary #

A withholding agent’s obligation to deduct and remit creditable tax attaches to the payment and the payor’s own status, not to whether the payee has a TIN or BIR registration. When paying an unregistered supplier or freelancer, ask for a TIN first, withhold and remit at the correct rate regardless of the answer, issue BIR Form 2307 using a placeholder TIN only as a last resort, and keep whatever transaction documentation is available to support both the withholding filing and the expense’s deductibility.