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Common Problems in the Preparation of the Employee Alphalist (1604 CF Attachment)

by | Jun 17, 2015 | Uncategorized

Every year, an Annual Alphalist of Employees are prepared and is mandatory be submitted to the Bureau of Internal Revenue on or before January 31st after the close of each year. The business world preparers of the alphalist encounters several issues that happens year after year without considering any possible solution. In this post we will learn about these common problems and issues, what are its causes, what are the risks, some simple recommendations to to follow to prevent these issues arising every year.

The preparation of alphalist is a team effort of the HR Department and the Accounting Department. In most cases, when HR policies fail to contribute its efforts, the lead time to print the Certificates of Withholding will be compromised. If the accounting/payroll department also failed to accurately imposed withholding of taxes against employees’ compensation, several adjustments and analysis will take place to delay the completion of 1604CF.

In summary, the common issues are as follows which were also discussed in detail in the succeeding section:

  1. Employees do not have TIN
  2. Employees with previous employers cannot supply their certificate of withholding (2316) from previous employer
  3. Ineffective/Inefficient way to summarize payroll details of employees in an annual basis
  4. Annualization of taxes results to tax deficiencies and/or tax refunds
  5. Employees with tax deficiencies do not want to pay the additional tax dues
  6. Certificates of withholding is not distributed on time
  7. Tax refunds are not given to employees on time, or not at all
  8. Alphalist of employees do not match the total compensation declared in the Annual FS
  9. Problems recur every period without a targeted solution

EMPLOYEES DO NOT HAVE TAX IDENTIFICATION NUMBER (TIN)

  • Possible cause – HR policy in the hiring process is not compliant with the rules of BIR
  • Risk/ Effect in the Preparation – Encoding in the Alphalist system is not possible if employee has no TIN, thereby delaying the preparation of employee Alphalist.
  • Recommended Solution/Best Practices – Implement mandatory obligation of employers to register/update employee records with BIR within the employee’s first 10 days at the company.Employee without TIN
    • File and submit BIR Form 1902 (Application for Registration)

    Employee with existing TIN

    • File and submit BIR Form 2305 (Certificate of Update of Exemption and of Employer’s and Employee’s Information)
    • In case Home RDO of employee is different from the Home RDO of the company, File and submit BIR Form 1905 (Application for Registration Information Update)

EMPLOYEES WITH PREVIOUS EMPLOYERS CANNOT SUPPLY THEIR CERTIFICATE OF WITHHOLDING TAX (2316) FROM PREVIOUS EMPLOYER

  • Possible cause – HR policy in the termination process does not service the rights of the outgoing employees.
  • Risk/ Effect in the Preparation- Inability of the newly hired employees within the calendar year to provide the Certificates of Withholding (BIR form 2316) from their previous employers may lead to inaccurate computation of annualized tax. In the absence of the 2316 from previous employer, the tax computation would result to a tax refund which was incompletely/inaccurately computed.
  • Recommended Solution/Best Practices- Implement mandatory obligation of the employers to provide the certificates of withholding (BIR Form 2316) to the outgoing employee. In the best practices, when the employee obtained its departmental clearances, the issuance of the withholding tax certificate is made together with the acknowledgement of receipt of the following:
    • Certificate of Employment
    • Acknowledgement Receipt of Final Pay/Separation Pay

HARDSHIPS IN SUMMARIZING PAYROLL DETAILS OF EMPLOYEES IN AN ANNUAL BASIS

  • Possible cause- The company is not maintaining a payroll database or failed to use a manual ledger for every employee in its current 201 file.
  • Risk/ Effect in the Preparation- It may take a lot of time and effort to summarize 24 sets of payroll sheets per employee in a year plus other incentives and commissions received/given, thereby, leading to delays in the encoding to the BIR 3.4 System.
  • Recommended Solution/Best Practices- Employ a payroll solution that can satisfy the following criteria:
    • Ability to generate reports to MS Excel database for analysis
    • Ability to generate the complete database of each payroll with each year
    • Ability to summarize in details year-to-date employee’s Basic Pay, Cola, OT, Holiday, NSD, Premiums, Incentives, Commissions, Deminimis benefits, Mandatory contributions, Withholding taxes, and Net Pay
    • Ability to maintain a Human Resource Information that can be generated on-the-fly when needed

ANNUALIZATION OF TAXES RESULTS TO TAX DEFICIENCIES AND/ OR TAX REFUNDS

  • Possible cause- The company does not implement the tax annualization procedures before the year ends rather it computes the taxes after the year was actually ended.
  • Risk/ Effect in the Preparation- Tax refunds are mostly understood by managers as expense of the company when in fact it’s a liability. Additional tax dues most likely require alphalist preparers to be creative in reducing the tax dues of the respective employees. If preparers misstated the details of the alphalist, there is a great possibility that any misstatement would lead to income tax exposure.
  • Recommended Solution/Best Practices- Annualization of taxes should be made on the months of November and December and any adjustments should be applied against these last two months of the year, NOT on January the following year.

EMPLOYEES WITH TAX DEFICIENCIES DO NOT WANT TO PAY ADDITIONAL TAX DUES

  • Possible cause- Inaccurate projection or calculation of per payroll period withholding taxes.Failure to withhold taxes on other taxable compensations such as incentives and commissions, and those that exceeded the respective thresholds of De Minimis Benefits.
  • Risk/ Effect in the Preparation- The employees with tax deficiencies will most likely feel disappointed/surprised on the imposition of additional tax due. Such employee might raise issues within the organization and in order to please such erring employee, alphalist preparers would find a way to reduce its tax due and may not be aware of future tax consequences.
  • Recommended Solution/Best Practices- Withholding taxes on all taxable compensations and employee benefits must be imposed.Employees with tax deficiencies should still pay the rightful amount of tax liability to be fair with everyone in the organization.

CERTIFICATES OF WITHHOLDING IS NOT DISTRIBUTED ON TIME OR NOT ALL DISTRIBUTED

  • Possible cause- All possible delays in the preparation of the Alphalist would lead to the none distribution of the Certificates of Withholding (BIR Form 2316)It may not be that important for the employer to distribute the certificates of withholding to the employees. Or the employer is not aware that he/she has certain responsibilities to its current employees and its outgoing employees.
  • Risk/ Effect in the Preparation- Non-distribution of the Certificates of withholding on or before January 31 the following year will result to several employees requesting the same certificates.Non-distribution of the Certificates of Withholding to the outgoing employees will lead to a problem issue/ consolidation issue to the subsequent employers within the calendar year.
  • Recommended Solution/Best Practices- It is mandatory that all employees be provided with certificates of withholding on or before January 31 the following year.Implement strict compliance on the requirements of BIR with regards to employee certificates of withholding.

TAX REFUNDS ARE NOT GIVEN TO EMPLOYEES ON TIME, OR NOT AT ALL

  • Possible cause- Inability of the management to comprehend the nature of refund.Inability of the accounting or HR department to annualize/ adjust its tax before the year ends.Employers may not be aware of its responsibility to release tax refunds.
  • Risk/ Effect in the Preparation- Possible litigation filed by an employee at the Department of Labor and Employment.
  • Recommended Solution/Best Practices- Always release tax refunds on or before January 25 of the following year.Tax refunds should also be given to outgoing employees/if not, a certificate of withholding with a proper amount of tax withheld should appear in the BIR form 2316.

ALPHALIST OF EMPLOYEES DO NOT MATCH THE TOTAL COMPENSATION DECLARED IN THE ANNUAL FS

  • Possible cause- There is an error in the alphalist or an error in the annual financial statements.There is an intentional misstatement on the amounts in the alphalist and/or on the amounts of compensation expense stated in the Annual FS. The Annual FS was not audited and the company just had it certified with an accredited CPA.Failure to include other forms of compensation in the Alphalist.
  • Risk/ Effect in the Preparation- Mismatch of employee alphalist between the FS would lead to possible disallowance of salaries and wages claimed as a deduction in the income tax return..
  • Recommended Solution/Best Practices- Do not misstate the Alphalist and the Salaries and wages in the FS. Have your FS audited by an independent auditor.

PROBLEMS RECUR EVERY PERIOD WITHOUT A TARGETED SOLUTION

  • Possible cause- Failure of the preparers to escalate these common issues to upper management/owners.Failure of management to seek resolutions to prevent such problems at year end.Overall ineffectiveness of HR policies and payroll solutions.
  • Risk/ Effect in the Preparation- Preparers of the alphalist will face so much pressure in completing all the requirements of the Alphalist preparation. Employee may feel disappointed with all of their rights being violated or neglected.
  • Recommended Solution/Best Practices- The preparation of the employee alphalists is an inter-department effort and should not be bourne with the preparer alone. The harmony of goals towards effective preparation is a work of the Admin, HR, and Accounting Departments.Firstly, HR processes should handle the registration of employees with BIR. Secondly, accounting/payroll department should consider monthly withholding to be accurately computed based on the withholding tax tables and also impose taxes on other taxable compensations such as incentives. And Finally, annualization of taxes should be made on the months of November and December to adjust any possibility of tax deficiencies and refunds at year end.Corporate social responsibility with respect to its employees should be guarded and the right of the employees to receive Certificates of Withholding (annually or upon separation), Tax Refunds should be always given.