Tax Alert No. 45 [Revenue Memorandum Circular No. 47-2020 dated 6 May 2020]

Guidelines on Temporary Measures Adopted by Taxpayers Relative to the Receipting/Invoicing Requirements During the Enhanced Community Quarantine (ECQ) in Relation to the Implementation of Republic Act No. 11469 or the “Bayanihan to Heal as One Act” 

The Commissioner of Internal Revenue (CIR) has issued Revenue Memorandum Circular (RMC) No. 47-2020 to prescribe guidelines for taxpayers utilizing the following temporary measures/workaround procedures during the ECQ period in relation to receipting/invoicing requirements:

1. Bureau of Internal Revenue (BIR) Printed Receipts/Invoices pursuant to RMC No. 28-2019;
   
2. Scanned Copy of Receipt/Invoice with Authority to Print (ATP) and electronically transmitted in JPEG, PDF or any equivalent format to the customer;
   
3. Computer-aided Receipt/Invoice in Excel format not covered by an ATP and similarly transmitted electronically in JPEG, PDF or any equivalent format to the customer;
   
4. Supplementary Receipts/Invoices were issued (i.e., Delivery Receipts, Acknowledgment Receipts, etc.) in lieu of the Principal Receipts/Invoices (i.e., Official Receipt and Sales Invoice);
   
5. Receipt/Invoice using the existing Computerized Accounting System (CAS) or its Components with approved Permit to Use (PTU) or Acknowledgement Certificate; however , the said receipt/invoice is being sent electronically or via electronic mail (e-mail) in JPEG, PDF or any equivalent format to the customer; or
   
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 the receipt/invoice is being sent electronically in JPEG, PDF or any equivalent format to the customer.
   

The following guidelines and procedures must be strictly observed:

1. Inform the BIR through a formal letter on the temporary measures/workaround procedures being implemented by 14 May 2020 (i.e., 3 days from the effectivity of the RMC), and indicating the following information:
   1. Name of taxpayer;
   2. Registered address of taxpayer;
   3. Taxpayer Identification Number with Branch Code;
   4. Temporary measures to be used/being used during the ECQ period, indicating the serial numbers of the receipts/invoices that will be issued;
   5. Statement that taxpayer is amenable to a post-verification of the reported sales during the period covered whenever the CIR so orders; and
   6. Signature of taxpayer or its authorized representative and designation
      
      The letter must be sent via email to:
      • For Non Large Taxpayers
        
        Client Support Service (CSS)
        Attention: Taxpayer Service Programs and Monitoring Division (TSPMD) at elenita.mariano@bir.gov.ph (for Regular Taxpayers)
        
        
      • For Large Taxpayers
        
        Large Taxpayers Assistance Division (LTAD) at mildred.reyes@bir.gov.ph (for large taxpayers registered under RDO 116, 125 and 126)
        
        Excise Large Taxpayers Regulatory Division (ELTRD) at ma.rosario.puno@bir.gov.ph (for Excise LTs registered under RDO 121 and 124)
        
        LT District Office Cebu at edenny.lingan@bir.gov.ph (for LTs registered under RDO 123)
        
        LT District Office Davao at emiliano.singco@bir.gov.ph and/or rdo_127@bir.gov.ph (for LTs registered under RDO 127)
         
2. Once the ECQ is lifted, the taxpayer must immediately provide or issue the duly authorized receipts/invoices to their clients/customers to cover all sales transactions that were issued temporary receipts/invoices. The actual date of transaction must be indicated in the authorized manual receipts/invoices to be issued and a copy of the temporary receipt/invoice attached to the file copy. The temporary receipts/invoices should be prioritized in the issuance of authorized receipts/invoices over current transactions.
   
   
   For taxpayers using receipting/invoicing system or CAS, where the date of the transaction is automatically indicated on the receipt/invoice, the actual date of the transaction should appear on the face of the system generated receipts/invoices in any manner feasible.
3. A Summary of Temporary Receipts/Invoices Issued must be submitted to the respective BIR Offices stated in Item No.1 above within 90 days from the date of the lifting of the ECQ, following the attached format (Annex A).