As we welcome the new year and slowly adapt to the new normal way of doing things, the Bureau of Internal Revenue is also adjusting to the new norm as they recently issued Revenue Regulation No. 05-2020, simplified policies on the application for registration of Computerized Accounting System (CAS), Computerized Books of Accounts (CBA) and/or its components, including Electronic Storage System (ESS), Middleware and other similar systems. All taxpayers intending to use CAS, CBA and/or its components shall not be required to secure Permit to Use (PTU).
Years prior, the release of PTU could take more than a year because of the lengthy process and voluminous applications at the BIR National Office. Last year, BIR issued RMC No. 10-2020, which suspends the issuance of PTU for CAS, CBA and components. The pending applications from the BIR National Office shall be handed over to the RDO where the taxpayer is registered and in lieu of a PTU number, taxpayers receive an Acknowledgement Certificate within three (3) days from the submission of documentary requirements. However, the scope of RMC 10-2020 was not clarified. New applicants were confused whether they should follow the new procedures given that the RMC suspended the issuance of PTUs. Taxpayers with approved CAS applications but PTU is pending on release were concerned if they will be classified as pending applications. The guidelines were not detailed with regards to the course of action for the post-evaluation checking.
Under the recently issued RMC No. 05-2021, the requirement of PTUs are no longer applicable, instead shall be registered subject to the following policies:
- Taxpayers shall submit the documentary requirements as provided under “Checklist of Documentary Requirements” (Annex A) - checklist of the documentary requirements and corresponding templates are available in the BIR website.
The following general requirements shall be complied:
- Sworn statement (Annex A-1) or joint sworn statement (Annex A-2), whichever is applicable, with duly attached accomplished Summary of System Description, Commercial Invoice/Receipts/Document Description, Forms/Records and Reports Specification (Annex A-3)
- sample print-out of Principal and Supplementary Receipts/Invoices
- sample print-out of Books of Accounts
- printed copy of audit trail
- duly accomplished and signed Standard Functional and Technical Requirements (Annex B)
If the software license is used under the name of the parent or affiliate:
- certification from the purchasing company allowing the taxpayer-applicant to use the same system
- The system must comply with the functional and technical standards provided under Annex B of the Circular. In case the BIR discovered that the said standards were violated during a post-evaluation or audit, the taxpayer shall be subject to penalties provided under RMO No. 07-2015 and other existing revenue issuances.
- Upon submission of complete documentary requirements, an Acknowledgement Certificate shall be issued within three (3) working days by the RDO where the taxpayer-user of the system is registered. BIR Form No. 1900 shall no longer be required.
- Though the system demonstration shall no longer be required prior to use, taxpayers shall ensure that the CAS/CBA and components thereof comply with the functional and technical standards provided under Annex B of the circular.
- All taxpayers with existing PTU shall not be required to apply for registration. and the previously issued PTU shall still be valid, except on the following circumstances:
a. PTU was revoked upon discovery of non-compliance with existing revenue issuances
b. Existence of major system enhancement or upgrade which will require filing of a new application for registration.
- In case of a major system enhancement in which a version of the system will contain new features and substantially improved functions, taxpayers must submit a new application for registration, such as but not limited to any of the following:
a.Change in the functionalities of the system particularly on enhancements
b. Additional or removal of modules or submodules within the system
c. Change in the system/software version or release number
d. All other enhancements that will be deemed as major system enhancement based on the recommendation of the technical evaluators
If a taxpayer is found to have used an enhanced or upgraded system without registering with BIR, the PTU originally issued shall be automatically revoked and may be subjected to applicable penalty.
- In case of a minor system enhancement, the taxpayer must submit a written notification to the RDO stating the minor specific enhancements of the system.
The BIR wants to make the taxpayer’s application easier by simplifying procedures in the registration of CAS, CBA and its components. This will help and encourage companies to ease their way of doing business by using any computerized accounting system. No more waiting for the release of PTUs.
Indeed, life changed when the pandemic started. It compelled a level of simplicity into our lives. We are now appreciating and discovering how a minimalist way of life can be attained. Welcome to the new normal.
Mara Eunice A. Apos is an Analyst of the Business Process Solutions/Outsourcing Division of P&A Grant Thornton. P&A Grant Thornton is one of the leading audit, tax, advisory, and outsourcing firms in the Philippines with 22 Partners and more than 900 staff members. We’d like to hear from you! Tweet us: @GrantThorntonPH, like us on Facebook: P&A Grant Thornton, and email your comments to firstname.lastname@example.org or email@example.com. For more information, visit our website: www.grantthornton.com.ph
As published in Mindanao Times, dated 25 January 2021