Scope of work for the CPA engaged through Anj's firm. Companion to the Anj Onboarding Brief. Draft for review — not yet sent.
Nana Bambi's
Ragay, Camarines Sur, Bicol, Philippines
An operating enterprise within the Bukal Collective family group
Prepared 27 June 2026
CPA — Agricultural Tax & Compliance Scope Brief
This sets the scope for the CPA engaged through Anj's firm. It is not a recruitment ad — the CPA is appointed via counsel. The enterprise is a vertically integrated farm-to-table operation across 12 spokes; the tax picture is correspondingly mixed.
Who does what (correcting earlier drafts):
- Live ops — POS (Loyverse) → nightly audit → finance apps, daily.
- Aileen — day-to-day admin, filing, payroll runs, GCash/POS, credit tracking.
- Grace — micro-finance & dispatch cost-watch at Agrupacion. NOT the bookkeeper.
- You (CPA) — certified books, BIR filing, tax planning, structure advice. Fed by a monthly package (by the 5th working day).
1 — Structure & income classification
Group: Bukal Collective (umbrella) over Nana Bambi's (operating co) + Mulkerrins Family Farm OPC (land) + a trust over shares. Income arises across 12 spokes simultaneously — correct classification per the NIRC is the first task. Indicative only; you confirm per item.
| Spoke | Income type | Indicative VAT |
|---|
| Alejandro's Café/Kitchen | Food service | VAT-able |
| Market & Butcher (Katayan) | Meat retail / value-add | Raw exempt; processed/value-add VAT-able |
| Panaderia | Baked goods retail/wholesale | VAT-able |
| Grocer / Merkado | Fresh produce, dairy, eggs, local goods | Raw agri exempt |
| Feeds & Supply | Trading (feed, milled product) | Feed largely exempt — confirm |
| Poultry | Eggs, broilers, breeding stock | Raw exempt; processed VAT-able |
| Livestock (incl. Dairy) | Cattle, goats, pigs; milk & cheese (creamery) | Live/raw & raw milk exempt; processed meat/dairy VAT-able |
| Marine & Seafood | Fresh/dried fish, ulang | Fresh exempt; dried/processed VAT-able |
| Regen Gardening & Produce | Vegetables, food forest | Raw agri exempt |
| Nursery, Soil & Compost | Seedlings, soil mix, compost | Seedlings exempt; inputs — confirm |
| Slow Food, Training & Community | Training / knowledge transfer | Service — VAT-able (confirm) |
| Deliveries (Cold Chain Distribution) | Distribution / delivery fees | Service — VAT-able (confirm) |
Advise whether consolidation or separation of income streams is more efficient, and the correct percentage-tax treatment for spokes below the VAT threshold.
Sister companies (separate entities, not spokes): Binihan Proper (off-site bakery + health-food hub) and Carolina (city café + events/functions venue) are separate businesses under the Bukal group — each with its own registration and returns, not income streams of the operating company. Advise how they consolidate at group level.
2 — Incentives, concessions & VAT
BOI is already decided — operationalise it, don't reassess it. Ragay = All Other Areas, Tier II Domestic Market Enterprise: 7 years ITH → 5 years 5% Special CIT → 20% from Year 13 (12-year incentive period); local business tax exempt throughout; 0% import duty on capital equipment; post-ITH EDR (extra deductions on power, labour, machinery depreciation). We need you to keep us compliant and capture every benefit.
- PEZA — Agrupacion is pitched as a PEZA-registered food-manufacturing enterprise (incentives on top of BOI). Advise on eligibility and interaction with the BOI ITH.
- Agricultural concessions — identify all applicable exemptions; Agri-Agra implications; TIMTA reporting for the incentives we hold; any Camarines Sur LGU concessions.
- BMBE — if total assets are under ₱3M, confirm eligibility (income-tax + minimum-wage relief) and how it interacts with BOI.
- VAT & percentage tax — registration threshold/timing on combined revenue; which streams are exempt (raw agri) vs VAT-able (food service, retail, events); input VAT recovery on construction, equipment and fleet (note 0% import duty already applies to capital equipment under BOI).
3 — Assets & depreciation
All construction/asset invoices are addressed to the registered business and entered on the date the invoice is paid — no exceptions. Asset register reviewed bi-annually (June & December). Confirm BIR-compliant schedules by class:
- Agricultural equipment & machinery
- Commercial vehicles & refrigerated fleet
- Buildings & permanent structures
- Cool rooms = insulated PIR/PU panel rooms (NOT reefer containers) — classify as building improvements / cold-storage infrastructure
- Aquaponic infrastructure at Pugod — ponds, grow beds, pumps, piping (classification & useful life)
- Reclassification when an asset changes function
Operations residence — FBT (needs your ruling): a residence is held as a company asset and may be provided to AIDO as the operations lead. Confirm: the correct FBT rate (understood 35%), the basis (market rental vs formula), reporting (BIR 1603Q quarterly), deductibility, depreciation, and whether construction-phase family use creates FBT before any employee occupancy.
Caveat that changes the answer: AIDO's relationship to the business is operational via the JVA (Bukal side), and his residency is pending (Balikbayan → 13A, arriving Sept 2026). Whether he is a compensated employee at all governs whether FBT/withholding even apply — please advise on the right structure.
Fleet — reefer truck, chiller van, livestock transport + support vehicles; Aileen is the sole borrowing entity. Confirm depreciation per type, deductibility of finance interest, whether assets sit in the operating company or Aileen's name for optimal treatment, BIR fuel-log substantiation, and input-VAT on purchase/operating costs.
4 — Employment & payroll tax
Three separate payrolls — keep them apart: (1) Nana Bambi's operating staff; (2) Mulkerrins Family Farm OPC — caretakers Jim & Jo (land-entity expense, outside the JVA); (3) Personal/household — Emily, nanny/housekeeper, off all business books. Mixing these is wrong for tax.
- Withholding schedules for operating staff; SSS / PhilHealth / Pag-IBIG employer rates & remittance; 13th-month timing.
- Year-end: BIR 2316 & 1604C; monthly 1601C.
- AIDO non-resident → resident: PH income-tax obligations from arrival; treatment during Balikbayan before 13A; TIN application; any employer obligation if he draws compensation. (Australian-side cessation handled there.)
5 — BIR compliance & filing calendar
We need a complete calendar from day one:
- Monthly/quarterly VAT (2550M/2550Q once registered)
- Quarterly & annual income tax (1701Q / 1702 per registration type)
- FBT quarterly (1603Q)
- Withholding on compensation (1601C) and expanded withholding on suppliers (0619E / 1601EQ)
- Annual information returns (1604E / 1604C)
- Books of accounts — format, registration & April stamping
- Official receipts / sales invoices — correct format for a multi-spoke enterprise
Loyverse & books: day-to-day runs on Loyverse POS. Advise whether the Loyverse export is BIR-acceptable as a subsidiary ledger and what books must be kept separately. Note: a POS receipt is NOT a BIR official receipt — every external sale still needs a BIR-registered OR, reconciled monthly.
6 — Strategic tax planning
Beyond compliance, give definitive recommendations (not a menu) on:
- At what revenue point individual spokes should be separately incorporated.
- Whether further holding/structure changes help — noting Bukal Collective already sits as the umbrella over the operating co, the land OPC and the trust.
- How to structure the family land/co-ownership for tax efficiency — reconcile with the current entities (Mulkerrins Family Farm OPC; trust options A/B) via Anj.
- CGT implications of future land transfers or purchases (e.g. Carolina CARP/DAR, Binihan Upper titles).
- Estate planning given the named successor trustee/beneficiary (Brighde).
- Any agricultural investment incentives that would change the optimal structure (alongside the BOI/PEZA position already held).
We need a CPA who understands agricultural enterprise and will give a definitive recommendation — tell us the right structure, explain why, and implement it. This brief is open to your correction.
Aidan & Aileen Mulkerrins
Nana Bambi's — Ragay, Camarines Sur