Creditable Withholding Tax Now Goes on Your Invoices: What RR 6-2026 and RMC 112-2026 Mean for Your Business

Your invoices need one more line. Revenue Regulations (RR) No. 6-2026 adds creditable withholding tax (CWT) to the list of information every invoice must contain. When a sale is subject to CWT, the invoice now has to show the CWT amount as a separate item.

The rule took effect in mid-October. Many businesses read it as "stamp every invoice," which caused confusion at the counter and in billing teams. On October 22, 2026, the BIR issued Revenue Memorandum Circular (RMC) No. 112-2026 to clear this up. It narrows the requirement to transactions that are actually subject to CWT, protects sellers who rely in good faith on their buyers, and gives system users until December 31, 2026 or March 31, 2027 to update their software.

Here is what changed, who it affects and what you should do this quarter.

What changed

RR No. 6-2026 amends Section 6(B) of RR No. 7-2024, the EOPT Act rules that list the mandatory information on an invoice (see our earlier guide on the shift from Official Receipts to Invoices). It adds a new item: "The amount of Creditable Withholding Tax, if applicable, shall be shown as a separate item."

Its transitory provision lets you keep using unused or unissued invoices until they run out, as long as the phrase "Less: Withholding Tax" is stamped conspicuously on the face of the invoice. Newly printed invoices must carry the same phrase before use. The regulation takes effect 15 days after publication in the Official Gazette or on the BIR website, whichever comes first. Grant Thornton Philippines reports that it was published on the BIR website on October 1, 2026, which puts effectivity at around October 16, 2026.

RMC No. 112-2026, dated October 22, 2026, clarifies how this works in practice. The key points:

• It applies only when the transaction is subject to CWT. A transaction is subject to CWT when the buyer or payor is required to withhold under the Tax Code and revenue issuances. CWT here means the creditable income tax withheld at source under Section 57(B) of the Tax Code and Section 2.57.2 of RR No. 2-98 (expanded withholding tax).
• B2B does not automatically mean CWT. A business-to-business sale is subject to CWT only if the buyer must withhold. An ordinary business-to-consumer (B2C) sale to a non-withholding agent is not subject to CWT, except a sale of real property (ordinary asset) to individuals.
• The buyer decides, and must tell you first. The buyer or payor determines whether it must withhold and should give you its withholding-agent status, income payment classification, ATC, rate, tax base and amount before you finalize the invoice.
• Good-faith reliance protects you. You may rely on the withholding information your buyer gives you. You won't be held liable solely because the buyer failed to give complete and correct information, unless you knew or had reason to know the transaction was subject to CWT.
• Invoice the full amount. Show the gross sale, the CWT as a separate item, and the net amount due. CWT is not a discount and does not reduce gross sales, VATable sales or the VAT base.
• Blank is fine when CWT doesn't apply. If an invoice has a CWT field and the sale isn't subject to CWT, you may leave it blank or write "N/A" or "0.00."
• Corrections go through a credit memo. If the buyer later decides CWT should have been withheld, you issue a BIR-registered Credit Memo referencing the original invoice. The original invoice stays valid and must not be cancelled or reused. The credit memo does not reduce gross sales or output VAT.
• Your tax credit still needs the certificate. The CWT on the invoice is informational. The buyer must still issue the withholding tax certificate (BIR Form 2307), and you still need it to claim the credit.
• Buyers are protected too. A missing CWT amount does not, by itself, disallow the buyer's input VAT or a properly substantiated expense.

Accepted labels: "Less: Withholding Tax," "Less: Creditable Withholding Tax" or "Less: CWT." RMC 112-2026 accepts all three.

Who this affects

• Service providers and suppliers that bill corporations, the government or other withholding agents. This covers professionals, contractors, lessors, commission agents and most B2B suppliers. You will issue the most invoices with a CWT line.
• Retail and walk-in businesses. RMC 112-2026 says sellers engaged mainly in ordinary B2C sales don't have to ask every customer whether they are a withholding agent. Unless the buyer identifies itself as one, you may issue the invoice without a CWT amount.
• Online sellers. When an e-marketplace, online platform or digital financial services provider withholds from your remittance under RR No. 16-2023, you invoice the consumer for the full amount. The invoice carries the CWT phrase, but the field may be left blank or marked "N/A" or "0.00," since the consumer is not the withholding agent. The platform shows the CWT in your settlement statement and issues the certificate. Don't issue a second invoice when the net remittance arrives.
• Businesses with POS, cash register machines, CAS or e-invoicing software. You need a system update, and RMC 112-2026 sets the deadlines.
• Buyers who are withholding agents. You now have a clear duty to communicate withholding details to suppliers before they bill you.

How to comply, by invoicing method

A few rules to note for system users:

• Once updated, the CWT phrase and field must appear permanently on every invoice output, even when the amount is blank.
• The system must keep the buyer's withholding-agent status, ATC, rate, tax base, CWT amount, gross amount and net amount due. It also needs an audit trail showing who entered or changed the withholding treatment.
• Changes limited to capturing, computing and displaying CWT count as a Limited System Change. You don't need a new CRM/POS or CAS registration for them, but you still have to meet any notification requirements under RMO No. 24-2023 and RMO No. 9-2021. Bigger changes, such as a new database, hosting environment or ownership, are Material System Changes and need the usual approvals first.
• Don't keep separate invoice series for CWT and non-CWT sales. Use one format and fill in the CWT field when it applies.

What you need to do

1. List your customers who withhold. Corporations, government agencies and top withholding agents usually withhold. Note the ATC and rate for each, and confirm them in your contracts or purchase orders.
2. Ask withholding customers to send their details before billing. Add a line to your quotation or billing instructions requesting their withholding status, ATC, rate and tax base. Keep these records, because RMC 112-2026 says you must substantiate good-faith reliance with documents.
3. Get a stamp for manual invoices. Use "Less: Withholding Tax," "Less: Creditable Withholding Tax" or "Less: CWT," with space for the amount. Place it near the total and net amount due, and never over the serial number, ATP details or VAT information. Stamp only when the transaction is subject to CWT.
4. Talk to your software provider now. Confirm whether your system is covered by mandatory e-invoicing (deadline December 31, 2026) or not (March 31, 2027). Ask for written confirmation that the change is limited to CWT, and file any required notification.
5. Update your bookkeeping entries. Record the full sale, then recognize CWT as a receivable or tax credit. Never book it as a sales discount.
6. Track the stamped system invoices. While you use the transitory method on POS, CRM or CAS invoices, keep a list of those invoices and reconcile them against your books and the Form 2307s you receive.
7. Set up a credit memo process. You'll need it when a buyer decides after invoicing that CWT applies.
8. If you buy from suppliers, brief your AP team. Send suppliers your withholding details before they invoice, and keep issuing Form 2307 on time.

Key dates

Key references

Conclusion

RR 6-2026 sounded like a big change, but RMC 112-2026 makes it manageable. You show CWT only when your buyer is required to withhold. You can keep your existing invoice stock. Your system update can wait until the end of 2026 or March 2027, depending on how you invoice.

The real work is in your process. You need withholding details from customers before you bill, a clean way to record CWT as a receivable, and a credit memo process for corrections. If you'd like help mapping which of your clients withhold, or checking your invoice templates before the deadlines, we're happy to review them with you.

References

1. Bureau of Internal Revenue. Revenue Regulations No. 006-2026: Amending the Mandatory Information Contained in the Invoice Pursuant to Section 6(B) of Revenue Regulations No. 07-2024 to Include Creditable Withholding Tax Information. 2026. https://bir-cdn.bir.gov.ph/BIR/pdf/RR%20No.%206-2026.pdf
2. Bureau of Internal Revenue. Revenue Memorandum Circular No. 112-2026: Clarifying the Provisions of Revenue Regulations No. 006-2026 on the Separate Presentation of Creditable Withholding Tax in Sales Invoices, and Providing Transitory Guidelines Thereof. October 22, 2026. https://bir-cdn.bir.gov.ph/BIR/pdf/RMC%20No.%20112-2026_redacted.pdf
3. Bureau of Internal Revenue. Digest of Revenue Regulations No. 7-2024 (Registration Procedures and Invoicing Requirements under the EOPT Act). April 11, 2024. https://bir-cdn.bir.gov.ph/BIR/pdf/RR%207-2024.pdf
4. Grant Thornton Philippines. Invoices must now disclose creditable withholding tax. October 12, 2026. https://www.grantthornton.com.ph/technical-alerts/tax-alert/2026/invoices-must-now-disclose-creditable-withholding-tax/
5. Daily Tribune. BIR extends deadlines for new CWT invoicing rules. October 23, 2026. https://tribune.net.ph/2026/10/23/bir-extends-deadlines-for-new-cwt-invoicing-rules
6. Daily Tribune. BIR sets 31 December e-invoicing deadline. September 23, 2026. https://tribune.net.ph/2026/09/23/bir-sets-31-december-e-invoicing-deadline