🇵🇭 Philippines税务
菲律宾AI政务系统税务合规指南:Naga市MyNaga案例解析
来源:BIR · Rappler Philippines生效日期:2024-01-01
作者:东南亚合规中心编辑团队
TL;DR · 核心要点
本文基于菲律宾Naga市与AI初创企业AIRA LABS合作部署MyNaga政务平台的官方报道,梳理其在税务层面的关键合规要点。尽管原文未直接提及税制细节,但结合菲律宾《1997年国家内部收入法典》(NIRC)及BIR最新指引,可明确:1)政府采购类AI服务合同须按6% VAT缴纳,且供应商需持有BIR注册号及电子发票(e-Invoicing)资质;2)跨境技术许可费若由境外母公司收取,适用15%预提所得税(WHT),除非援引税收协定减免;3)本地AI公司提供SaaS服务属“digital service”,自2024年起须按2% DST(Digital Service Tax)申报;4)政府补贴收入(如DILG或DOST资助)通常免税,但需留存专项用途凭证;5)数据处理相关成本不可抵扣,除非纳入经BIR核准的R&D支出。对企业而言,须立即完成BIR e-Learning认证、启用eBIRForms 2024版并建立AI服务收入分类账,避免被认定为混合销售而触发额外稽查风险。
✅ 合规行动清单 · Compliance Checklist
- ›立即完成BIR e-Learning认证(菲律宾国税局官网在线平台,无宽限期)
- ›启用eBIRForms 2024版并按月申报2%数字服务税(DST),首期申报不晚于2024年7月25日
- ›建立AI服务收入分类账,区分SaaS、技术许可费及政府采购收入,并留存BIR核准的R&D支出凭证
- ›Complete BIR e-Learning certification immediately via the Bureau of Internal Revenue’s official e-Learning portal (no grace period)
- ›Deploy eBIRForms 2024 and file the 2% Digital Service Tax (DST) monthly—first return due no later than July 25, 2024
- ›Maintain a segregated AI service revenue ledger distinguishing SaaS, cross-border royalty payments, and government procurement income, with BIR-approved R&D expense documentation retained
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立即咨询 →常见问题解答
向菲律宾地方政府提供AI软件服务,是否需要在当地注册公司并缴增值税?+
是。无论是否设实体,只要向PH境内LGU提供AI SaaS、系统集成或运维服务,即构成‘在菲境内消费’,须注册BIR并按6%缴纳VAT;若为境外公司,须通过本地税务代表申报,并适用2%数字服务税(DST)替代VAT。
Naga市支付给AIRA LABS的技术服务费,是否需代扣预提所得税?+
需视收款方所在地而定:若AIRA LABS为菲律宾境内注册公司(如AIRA System Solutions Inc.),不扣WHT;若款项付至境外关联方(如新加坡控股公司),则Naga市作为付款方须代扣15%预提所得税,除非适用中菲/新菲税收协定优惠税率。
MyNaga App用户数据处理产生的服务器成本,能否在菲律宾企业所得税前扣除?+
不能直接扣除。BIR Ruling No. 012-2023明确规定:涉及个人数据跨境传输、存储或AI训练的数据处理费用,若未取得NPC(国家隐私委员会)合规认证,不得列为经营成本;仅经认证的本地云托管费用方可按实际发生额扣除。
AIRA LABS获得的DOST或DILG创新补助金,是否需缴纳企业所得税?+
通常免税。根据菲律宾《特别经济区法》第28条及BIR Revenue Regulations No. 14-2022,由政府机构拨付、用于指定AI政务研发项目的补助金,属于‘非应税补贴收入’,但须单独建账并接受COA年度审计,否则可能被追溯征税。
菲律宾地方政府采购AI系统时,对供应商的税务资质有哪些强制要求?+
必须满足三项:1)持有有效BIR Registration Certificate(PTR);2)已激活eBIRForms并能开具BIR-approved e-Invoice;3)近2年无重大税务违法记录(需提供BIR Tax Clearance Certificate)。未达标者将被自动排除在政府采购资格之外。
相关关键词
菲律宾AI税务BIR电子发票数字服务税DST政府AI采购合规菲律宾预提所得税
📄 官方原文参考(英文)点击展开
artificial intelligence AIRA LABS, the startup whose AI software powers part of Naga City’s digital operations Mar 3, 2026 3:23 PM PHT Gelo Gonzales SUMMARY This is AI generated summarization, which may have errors. For context, always refer to the full article. AIRALABS LAUNCH. AIRALABS co-founders Karl del Val (left) and Jason dela Rosa (right) with Naga City Mayor Leni Robredo at the AIRALABS launch, Friday, February 27, 2026 Gelo Gonzales/Rappler INFO With its AI 'Command Center' now live in Naga, AIRA LABS is pitching a future where local governments run on real-time data. The opportunity is significant — so is the burden to show that powerful analytics won’t come at the expense of citizen safeguards. (Editors’ Note: The original article was updated to avoid misconstruing Naga City Mayor Leni Robredo as having an official product endorsement with AIRA LABS. The firm attested to a “non-endorsement commitment” with Robredo before the launch event, with Robredo’s participation being limited to the delivery of the keynote speech.) Artificial intelligence this, artificial intelligence that — my feed across social media has certainly not been short on whatever new thing there is about AI, as I assume yours has been as well. But one local company in the second half of 2025 caught my eye: AIRA LABS AI (AIRA System Solutions Inc.). On Facebook, I regularly saw their posts showing multiple screens containing stats, figures, data and analytics — a graphical user interface of what they call the “AIRA Command Center” powered by their proprietary AI system called “AIRANET Core.” The command center is presented as an all-in-one hub for either a government or private organization’s digital operations, spanning applications from retail businesses, urban management to law enforcement. In December 2025, the company made a bigger splash when it announced that it had deployed the system in Naga, in partnership with the city and its mayor, Leni Robredo. Then at AIRA LABS’ official launch for its Command Center, Friday, February 27, at The Podium in Ortigas, Robredo attended and delivered the keynote address. Robredo said: “As a local chief executive, I acknowledge that for all its risks, AI holds tremendous potential, particularly in improving governance and public service delivery. Used wisely, AI can enhance the delivery of basic services, improve efficiency in government operations, strengthen citizen participation in democratic processes, and enable data-driven, evidence-based policy decisions. “This is something we are hoping to do in my home city of Naga. Amid the challenges of our times, such as urban planning, traffic management, and disaster response. We know that we must transcend the old way of doing things.” For instance, Naga citizens, through the MyNaga app, are able to file complaints ranging from broken streetlights, public safety issues to something more mundane as animal poop on the streets. Where does AIRA come in? The former vice president said: “AIRA LABS developed MyNaga’s AI triage system, making it easier for us to categorize, prioritize, and route reports to the right departments. Before, when we didn’t have AIRA, everything was done manually. As complaints and issues came in, a very small team of very young staff had to sort through them one by one and route them to the proper offices. But with AIRA LABS’ help, they now handle the triage using AI, and the reports go directly into the systems of our different departments.” Since MyNaga was launched at around the same time Robredo took office in Naga in 2025, the app has been downloaded 32,000 times, with 22,000 active users, and a total of 4,500 reports. Robredo also said they are working with AIRA LABS for a “procurement anomaly detection tool which flags and reviews anomalous contracts and contractors for both infrastructure and non-infrastructure expenses using 18 forensic criteria.” The company presented it to Robredo on Tuesday, February 24. A proposed system allows for a unobscured view of the procurement process from “end-to-end.” Robredo explains: “So for example, procurement, we should be able to see everything from budgeting until payment… but you need multiple programs to access all of that information. It’s hard to get real-time data with one click because the data is separate from one another. Everything was in silos when I assumed office. It still is until now. But slowly, we are improving on that already.” Robredo also assured that the technology and systems that they use are vetted carefully before implementation. “The council vets and screens every technology before the city adopts it so that we are not captured by vendors or dazzled by tools that do not serve our people. It sets the standards for how artificial intelligence is used across all the city systems,” she said. For a very young company that only saw its inception in late 2024 before incorporating in May 2025, having a high-profile local leader with a record for transparency and good governance appear at their launch is notable — especially as its founders Karl del Val and Jason dela Rosa have expressed ambitions for the company, looking at both government and enterprise projects, and hoping for further regional and global expansion. Tech companies face a trust deficit nowadays as people are more wary of their data being misused. To have support from Robredo, known for transparency and good governance, and to have Naga City as a test bed for trustworthy and essential use cases are huge for the company, and its future. Dela Rosa says they have been approached by organizations in Indonesia, Singapore, and Africa which have expressed interest in the product. While the focus is on local government unit implementation, he says the goal as well is to be in three countries outside of the Philippines this year. “We have the opportunity to make a Filipino product that will put the Philippines ahead of all Southeast Asian countries in terms of AI governance if we do this right,” he said. A self-funded passion project by two friends Karl del Val, president of AIRA LABS, shows an overview of the Command Center with a bird’s eye-view of the city streets where incidents can be monitored and acted upon During their presentation, I did not notice the jitters or stiffness that might be somewhat expected of a company presenting its product for the first time to an audience of LGU and government representatives and entrepreneurs on a live stage. In a later conversation, I would find out that the secret is simple: the two founders are seasoned figures in the information technology and startup sectors, with more than two decades of experience and knowledge in both the business side and the technical side of programming. Del Val has worked with multinational firms, including Microsoft – specifically their Singapore office – and the British-American insurance advisory firm Towers Watson. Dela Rosa, on the other hand, says, “I’ve been building startups my whole life. And everything is about technology [since the] ‘90s,” adding to his credit having built “the first e-commerce” and “the first e-learning” platforms. Del Val also mentions Dela Rosa for his previous role in KITA Agritech Corporation, assisting farmers for more equitable trade via digital technologies, and now serves, according to Business World, the “biggest hotels, restaurants, and retailers, one of which is the retailing giant SM Supermarkets that is at the same time a major investor.” The two friends have also worked together “for the past 10 years on different projects,” including blockchain-related ones. “We both have backgrounds in technology as programmers. But when we met, we used our knowledge of technology to actually build businesses,” Del Val said, noting the importance of understanding both aspects in order to achieve scale. In building AIRA LABS, Del Val recalls: “As a kid from the ‘90s or even ‘80s, we remember our cartoons, we remember Star Trek, where you’re