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BIR 2316: Item 29 and 39 mapping

If you've noticed that salaries are reflected differently in Fields 29 and 39 of BIR Form 2316, don't worry—this is expected behavior and is designed to comply with the Bureau of Internal Revenue (BIR) reporting guidelines.


How Sprout populates these fields

Field 29 – For Minimum Wage Earners (MWEs)

Field 29 contains only the salaries of employees classified as Minimum Wage Earners (MWEs).

This follows the reporting requirements under BIR Revenue Memorandum Circular (RMC) No. 7-2021, as implemented in the latest BIR software version released through RMC No. 61-2024.

Field 39 – For Non-MWEs

Field 39 includes the salaries of non-Minimum Wage Earners (non-MWEs), including employees whose annual taxable compensation is below ₱250,000.

Even if an employee has no income tax due because their annual compensation is below the tax-exempt threshold, their salary is still reported under Field 39 if they are not classified as an MWE.

Why are MWEs and non-MWEs reported separately?

The BIR requires employers to report compensation for MWEs and non-MWEs separately.

Under RMC No. 7-2021, specifically Annex C (Guidelines for accomplishing BIR Form 1604-C), employers must prepare separate income schedules in the Alphalist for:

  • Minimum Wage Earners (MWEs)
  • Non-Minimum Wage Earners (non-MWEs)

Because of this requirement, non-MWE salaries should not be reported in Field 29. Doing so may result in inconsistencies between the employee's BIR Form 2316, the Alphalist, and BIR Form 1604-C.

How does this help ensure compliance

Sprout follows the BIR-prescribed reporting format to ensure that:

  • MWE and non-MWE compensation are reported in the appropriate fields.
  • BIR Form 2316 aligns with the corresponding Alphalist and BIR Form 1604-C.
  • Employers minimize the risk of discrepancies during BIR validation or tax assessments.

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