Tax Alerts

Guidelines on invoicing requirements during ECQ

(Revenue Memorandum Circular No. 47-2020, May 11, 2020)

This Tax Alert is issued to inform all concerned on the guidelines on the issuance of receipts/invoices by taxpayers having difficulty in complying with the receipting/invoicing requirements during the enhanced community quarantine (ECQ).

In case the duly authorized or approved receipts/ invoices are inaccessible or unavailable during ECQ, the taxpayers may opt to use any of the following:

  1. Bureau of Internal Revenue (BIR) Printed Receipts/Invoices;
  2. Scanned Copy of Receipt/Invoice with ATP electronically transmitted to the customer;
  3. Computer-aided Receipt/Invoice in Excel format not covered by an ATP and electronically transmitted to the customer;
  4. Supplementary Receipts/Invoices (i.e., Delivery Receipts, Acknowledgment Receipts, etc.) in lieu of Principal Receipts/Invoices;
  5. Receipt/Invoice using the existing Computerized Accounting System (CAS) or its components with approved PTU or Acknowledgement Certificate sent electronically or via e-mail to the customer; and
  6. Receipt/Invoice generated from a newly developed receipting/invoicing software or CAS or its Components without duly approved PTU or Acknowledgment Certificate, which was used to temporarily generate/issue the receipts/invoices and sent electronically to the customer.

Compliance Requirements

Any taxpayer who adopted the above work-around procedures shall comply with the following requirements:

  1. Send a formal letter informing the BIR of the work-around procedure being implemented. The letter shall be sent via electronic email to designated e-mail addresses of Client Support Service of the BIR for Non-Large Taxpayers and appropriate Large Taxpayers Division for Large Taxpayers within 3 days from effectivity of the circular.
  2. Once the ECQ is lifted, issue the duly authorized receipts/invoices to the customers to cover all transactions for which temporary receipts/invoices were issued. The duly authorized receipts/invoices shall bear the actual date of the transaction. In cases of receipts issued from a CAS or other receipting system which automatically indicates the date generated, the actual date of the transaction should be indicated on the face of the receipt in any manner feasible.
  3. Submit the “Summary of Temporary Receipts/Invoices Issued” pursuant to Annex A of the RMC to the respective BIR offices within 90 days from the date of lifting of ECQ.

Please refer to the copy of the RMC posted in our website for the designated email addresses and the format of the “Summary of Temporary Receipts/Invoices Issued”.

Taxpayers who have access to the receipts/invoices but with expired ATP shall follow the work-around procedures under RMC No. 41-2020.