The Bureau of Internal Revenue (BIR) has released Revenue Regulations (RR) No. 11-2024, which amended certain transitory provisions of RR No. 7-2024 and extended the deadlines for compliance with the new invoicing requirements under Republic Act No. 11976, otherwise known as the Ease of Paying Taxes (EOPT) Act.
Below are the amendments introduced by RR No. 11-2024:
No Replacement Required for BIR COR with Registration Fee
Business taxpayers are not required to replace their existing BIR Certificate of Registration that displays the Registration Fee.
Using Official Receipts (OR) as Supplementary Document
Service-oriented taxpayers may continue to use their remaining ORs as a supplementary document, provided that the phrase “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.” is stamped on the face of the document.
Conversion and Use of Remaining ORs and Billing Statements as Invoices
On the other hand, taxpayers may also convert and use their remaining ORs as Invoices and convert billing statements, statements of account, or statements of charges into Billing Invoices until fully consumed. These documents shall be considered valid for claiming input tax by the buyer/purchaser and can serve as proof of both sales transactions and payment at the same time for the period issued from April 27, 2024, until they are fully consumed, provided that the amount of sales, VAT amount, registered name and TIN of both buyer and seller, description of goods or nature of services, and the date of transaction, as enumerated by Section 3(D)(3) of RR No. 7-2024, are properly indicated in such converted invoice
Furthermore, effective April 27, 2024, any manual/loose-leaf ORs issued without a stamped “Invoice” will be ineligible for input tax claims.
Deadline and Requirements for Reporting and Conversion of Unused ORs and Billing Statements into Invoices
The stamping of ORs as Invoices and converting billing statements, statements of account, or statements of charges into Billing Invoices by taxpayers does not need approval from any BIR office. However, taxpayers who choose to convert their ORs and billing statements shall submit an inventory of unused ORs/Billing Statements/Statements of Account/Statements of Charges indicating the number of booklets and corresponding serial numbers on or before July 31, 2024, in duplicate copies, to the BIR office where they are registered.
Transition and Compliance Guidelines for Taxpayers Using CRM, POS, E-invoicing and CAS
Taxpayers using Cash Register Machines (CRM), Point-of-Sale Systems (POS), E-receipting or E-invoicing systems may change the word “Official Receipt” to “Invoice” or any name describing the transaction without the need to inform the RDOs having jurisdiction.
Meanwhile, the system enhancement for taxpayers using duly registered Computerized Accounting Systems (CAS) or Computerized Books of Accounts (CBA) with Accounting Records (AR) will require them to update their system registration following the existing policies and procedures for registering the use of CAS or CBA with AR.
Reconfiguring machines and enhancement of CAS/CBA with AR shall be undertaken on or before December 31, 2024. Any extension due to reconfiguration/enhancements of the system must be approved by the concerned Regional Director or Assistant Commissioner of the Large Taxpayers Services, which shall not be longer than six (6) months from December 31, 2024.
The serial number of the renamed Invoices to be issued by CRM/POS machines, e-receipting, or electronic invoicing software, CAS, or CBA with AR shall start by continuing the last series of the previously approved ORs and shall submit notice after the completion of reconfiguration/enhancements, indicating the starting serial number of the converted Invoices within thirty (30) days from the completion of machine/system reconfiguration/enhancements or on December 31, 2024, whichever comes first.
Furthermore, documents issued by CRM/POS machines, e-receipting, or electronic invoicing software, CAS, or CBA with AR containing the word “Official Receipt” from April 27, 2024 until the completion of system enhancements shall be considered as valid for claiming input tax by the buyer until December 31, 2024, or until the completion of the system enhancements, whichever comes first, provided that the amount of sales, VAT amount, registered name and TIN of both buyer and seller, description of goods or nature of services, and the date of transaction, as enumerated by Section 3(D)(3) of RR No. 7-2024, are properly indicated in such converted invoice, and the system-generated "OR/Billing Statement/Statement of Account/Statement of Charges" is converted by striking through the said terminologies and stamping the word "Invoice/Billing Invoice" on the document.
Compliance and Penalties for Non-Conversion of Official Receipts to Invoices After December 31, 2024
Issuance of OR, with or without strikethrough, generated by CRM/POS machines, e-receipting, electronic invoicing software, CAS, or CBA with AR for the sale of goods or services after December 31, 2024, or until the completion of machine/system reconfiguration/enhancement, whichever comes first, and issuing manual/loose-leaf ORs without converting them to "Invoices" for the sale of goods or services starting April 27, 2024, will not be considered as evidence of sales of goods or services and shall be tantamount to failure to issue or non-issuance of Invoices. Such failure is subject to a penalty of not less than Php 1,000.00 but not more than Php 50,000.00 and imprisonment of two to four years pursuant to Section 264(a) of the Tax Code.
Further extensions of deadlines in the transition period prescribed may be granted as deemed necessary by the Commissioner of Internal Revenue.
These Regulations took effect on June 13, 2024, immediately upon publication on the BIR Official Website.
Please be guided accordingly.
Source:
P&A Grant Thornton
Certified Public Accountants
P&A Grant Thornton is the Philippine member firm of Grant Thornton International Ltd
As published in SunStar Cebu, dated 20 June 2024
