The Bureau of Internal Revenue (BIR) has extended its deadlines for using old Official Receipts (ORs) and for complying with the new invoicing requirements under the Ease of Paying Taxes (EOPT) Law.
Revenue Regulations (RR) No. 11-2024, issued on June 13, 2024, amends the transitory provisions of RR 7-2024, a key regulation issued on April 11, 2024 to implement the guidelines of EOPT and provide a framework for taxpayers to comply with the new invoicing requirements.
Among the major amendments in RR 11-2024 is that taxpayers may continue to use as supplementary document the remaining ORs that were not converted into invoices until such time these unconverted ORs are fully consumed. This is provided that the phrase “This document is not valid for claim of input tax” is stamped on the document.
When used as a supplementary document and not as invoice, the unused OR is no longer valid evidence of sales and for claiming of expenses and input tax. Instead, it will be considered as proof of payment or collection.
Another key revision by RR 11-2024 is that taxpayers may not only convert and stamp the unused remaining ORs as Invoice, they can also opt to convert and stamp the Billing Statement/Statement of Account/Statement of Charges as Billing Invoice and use them until fully consumed. Previously, under RR 7-2024, these converted documents were valid only until December 31, 2024.
The additional requirement, however, is that these converted Invoices/Billing Invoices must contain the required information, including the quantity, unit cost, and description or nature of the service. If the required information is not readily available in the converted documents, these may be stamped in order to comply with these requirements.
RR 11-2024 further declares that the converted Invoices/Billing Invoices shall be considered valid for claiming input tax and proof of both sales transaction and payment at the same time for the period issued from April 27, 2024 until they are fully consumed. This is provided that there is no missing information as enumerated under Sec. 3(D)(3) of RR 7-2024. Any manual or loose leaf “Official Receipt” issued without a stamped “Invoice” will be considered supplementary documents and ineligible for input tax claims.
The stamping of converted Invoices or Billing Invoices does not require approval from the Revenue District Offices/Large Tax Offices/Large Tax Divisions. Taxpayers must still obtain newly printed invoices with an Authorized to Print (ATP) before fully consuming the converted Invoice or Billing Invoice.
At the same time, under RR 11-2024, taxpayers still need to submit the Inventory List of Unused Official Receipts to BIR to report the number of Official Receipts remaining for use as Invoices. The deadline has been extended to July 31, 2024 to give businesses more time to compile and submit accurate inventory reports.
Further, RR 11-2024 has extended to December 31, 2024, the reconfiguring by businesses of their Computerized Accounting Systems (CAS), Computerized Bookkeeping Applications (CBA), and Point of Sale (POS) systems with Accounting Records (AR). This is an extension from the June 30, 2024 deadline set by RR 7-2024.
It may be extended for a further six months from December 31, 2024, subject to approval from the concerned Regional Director or Assistant Commissioner of the Large Taxpayers Service.
After completing the system changes, businesses must notify the renaming of their ORs to CRM/POS/CAS/CBA with AR within 30 days or by December 31, 2024, whichever comes first, to ensure that all documentation remains accurate and compliant.