Let’s Talk Tax
By Christian Derick D. Villafranca

2026 has been a breakthrough year for Original Pilipino Music (OPM) and Pinoy Pop (P‑pop) artists, marking a pivotal moment as Philippine artists gain growing international recognition. The successful performance of BINI at the recently concluded Coachella 2026 captivated festival goers through their powerful vocals, dynamic choreography, and striking visuals.
SB19 is also making waves internationally with its upcoming appearance at Lollapalooza 2026, further showcasing Filipino talent to the world. Together, these achievements demonstrate that P-pop artists are capable of producing world-class performances that rival those of other international acts.
With the blooming popularity of P-pop, artists are beginning to reap the rewards of their hard work and perseverance. This success is evident not only in heightened public recognition but also in fans’ growing willingness to spend in support of their idols, signaling a more mature and sustainable creative market. As the saying goes, “It takes a village to raise a child,” and in the entertainment industry, success is likewise not driven by artists alone but by an interconnected ecosystem of stakeholders working both behind the scenes and alongside the performers.
Naturally, where income flows, taxes follow. As the industry continues to thrive, understanding how income earned by each participant in this ecosystem is taxed under Philippine law becomes essential, not only for regulatory compliance but also for fostering the industry’s longterm sustainability.
ARTISTS AND PERFORMERS
Artists and performers earn income from various sources, including talent fees, appearance fees, and performance fees arising from concerts, fan events, and shows, which, as a general rule, are all subject to income tax unless expressly exempted by law.
In the Philippines, artists are generally considered independent contractors and are classified for tax purposes as self-employed individuals or persons engaged in trade or business as sole proprietors. Accordingly, the freelance artist is subject to the following tax obligations, namely: (1) income tax, imposed either at graduated income tax rates ranging from 0% to 35%, or an 8% tax on gross income, if qualified to avail of the option. Availing of the 8% income tax is in lieu of both the graduated income tax rates and the 3% percentage tax; (2) business tax imposed as a 12% Value-Added Tax (VAT), applicable to VAT-registered persons or those mandatorily required to register for VAT upon exceeding the P3,000,000 gross annual sales threshold; or a 3% percentage tax, if non-VAT registered and not availing of the 8% income tax option.
Talent fees received by artists are subject to expanded withholding tax (EWT), with the applicable rate depending on whether the artist is an individual or a non‑individual (corporation or juridical entity) and whether the applicable gross‑sales threshold is exceeded. Individual artists whose gross annual sales do not exceed P3,000,000 are subject to 5% EWT, provided that a duly notarized sworn declaration is submitted to the withholding agent; otherwise, a 10% EWT rate applies. On the other hand, non-individual artists, such as corporations or other juridical entities, are subject to a 10% EWT if their gross annual sales do not exceed P720,000, subject to the submission of a notarized certification to the withholding agent; otherwise, a 15% EWT rate applies.
These freelance artists are subject to compliance requirements, which include maintaining BIR registration, keeping books of account, filing tax returns and paying taxes on time, withholding and remitting applicable taxes on income payments, and issuing invoices, among others.
CONCERT PROMOTERS AND PRODUCERS
The taxable income of concert promoters and producers includes earnings from ticket sales, sponsorships, and production fees. Such income is subject to individual or corporate income tax, whichever is applicable, and business tax — either VAT or percentage tax, as applicable.
In addition to these taxes, concert promoters and producers are required to withhold and remit applicable taxes on payments to various suppliers and service providers. These include payment for concert venue rentals, which is usually subject to 5% withholding tax; talent fees paid to artists or performers, which are subject to withholding tax ranging from 5% to 15%, as applicable; and payments for marketing and promotional services, logistics, lighting and sound services, and other related expenses, which are generally subject to 1% or 2% withholding tax, as applicable.
TICKETING PLATFORMS
Ticketing platform companies earn income from convenience fees, commissions, and similar charges, which are subject to income tax and business tax under the Philippine tax laws.
As electronic marketplace operators, ticketing platforms are likewise required to withhold one‑half percent (½%) on the gross remittances made to concert producers for tickets sold or paid for through their platform or facility, in accordance with applicable withholding tax regulations.
COPYRIGHT OWNERS AND ROYALTY RECIPIENTS
When sound recordings published for commercial use are broadcast to the public (e.g., via television or radio) or publicly performed (e.g., during live events) with the intention of generating or enhancing profit, the use of that music generally gives rise to a Single Equitable Remuneration (SER) obligation. SER represents royalty due to the owners of copyright — such as composers, lyricists, and music publishers — in the sound recording and related works for the commercial exploitation of their music. In practice, these royalties are not paid directly to individual composers or rights holders but are instead collected by authorized collective management organizations (CMOs). The CMOs pool the collections from users of music and thereafter distribute the net royalties, after deducting administrative costs, to their member rights holders.
Moreover, singers or performers are likewise entitled to royalties arising from the broadcast, public performance, and reproduction of their performances fixed in sound recordings or audiovisual recordings. Like the arrangement for copyright owners, these royalties are collected from licensees by an accredited CMO and distributed to member performers in accordance with the applicable distribution rules.
Apart from performance-related royalties, copyright owners may also earn mechanical royalties from streaming activities and from the sale of physical and digital copies of copyrighted music.
For tax purposes, a distinction must be made as to whether royalties earned from copyrighted music constitute active income or passive income, as this determines the applicable tax treatment.
Where the taxpayer is actively engaged in the business of licensing or sub-licensing musical compositions and copyrighted music — as evidenced by its records (e.g., articles of incorporation and business registrations) — the royalty income is considered active income and is subject to regular corporate income tax (RCIT). Otherwise, the royalty income is treated as passive income, subject to final withholding tax at 10% for individuals and 20% for domestic corporations. In either case, royalty income is subject to business tax, as applicable.
DIGITAL PLATFORMS AND STREAMING SERVICES
Today, content from artists and performers is widely accessed through digital streaming platforms, which may be operated by either a resident digital service provider (DSP) or a non-resident digital service provider (NRDSP).
VAT-registered resident DSPs are generally subject to the same tax rules applicable to domestic companies and are therefore subject to income tax and VAT, unless expressly exempt by law.
On the other hand, NRDSPs are generally subject only to 12% VAT on digital services consumed in the Philippines, pursuant to the Republic Act. No. 12023, effective June 2, 2025. The manner of VAT remittance depends on whether the transaction is classified as business-to-business (B2B) or business-to-consumer (B2C). In both cases, NRDSPs are required to register with the Bureau of Internal Revenue (BIR), file quarterly VAT returns (BIR Form No. 2550DS), and comply with applicable reporting requirements. For B2B transactions, VAT is remitted to the BIR by the Philippine business customer under the reverse charge mechanism, while for B2C transactions, the NRDSP directly remits the VAT to the BIR.
Ultimately, the rise of OPM and P-pop artists is a story of talent and collective effort. What began as passion now generates significant income for artists and supporting enterprises alike. The taxes generated from this growth contribute directly to nation-building, proving that when our creative industries thrive, they uplift the entire country together, in our Islang Pantropiko.
Let’s Talk Tax is a weekly newspaper column of P&A Grant Thornton that aims to keep the public informed of various developments in taxation. This article is not intended to be a substitute for competent professional advice.
Christian Derick D. Villafranca is a senior manager from the Tax Advisory & Compliance practice area of P&A Grant Thornton, the Philippine member firm of Grant Thornton International Ltd.