Tax Alert No. 27 [Revenue Regulation (RR) No. 11-2024 dated 13 June 2024]

Jun 18, 2024

Amending the transitory provisions of Revenue Regulations No. 7-2024 relative to the deadlines for compliance with the invoicing requirements

Please be informed that RR No. 11-2024 has been issued to amend the transitory provisions of RR No. 7-2024 and extend deadlines for compliance with the new invoicing requirements under the Republic Act No. 11976, otherwise known as Ease of Paying Taxes (EOPT) Act, pursuant to the provisions of Section 244 and 245 of the Tax Code, in relation to Section 47 of the EOPT Act.

The following are the salient points of the abovementioned revenue regulations:

Certificate of Registration (COR) reflecting the Registration Fee (RF)
Business taxpayers are not required to replace its existing BIR COR that displays the RF. Updating the COR is only necessary if there are changes to the registration information, excluding RF, reflected on the COR.
Unused official receipts (OR)
- Taxpayers may continue the use of the remaining ORs as supplementary documents. All unused or unissued OR may still be used as a supplementary document upon the effectivity of these Regulation until fully consumed, provided that the phrase “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX” is stamped on the face of the document.
- Taxpayers may convert and use the remaining OR as Invoice and convert the Billing Statement/Statement of Account/Statement of Charges into Billing Invoice.
- The converted “Official Receipt” or “Billing Statement/Statement of Account/Statement of Charges” shall contain the required information provided under Section 6(B) of RR No. 7-2024, including the quantity, unit cost and description or nature of service pursuant to Sec. 237 of the Tax Code.

The above documents shall be considered valid for claiming of input tax by the buyer/purchaser and can serve as proof of both sales transaction and payment at the same time for the period issued from April 27, 2024 until they are fully consumed, provided that the converted Invoice/Billing Invoice to be issued bears the stamped “Invoice/Billing Invoice” and there is no missing information as enumerated under Section3(D)(3) of RR No. 7-2024.

Cash Register Machines (CRM) and Point-of-Sales (POS) Machines and E-receipting or E-Invoicing Software
- Taxpayers using CRM/POS/E-receipting/E-invoicing may change the word “Official receipt” to “Invoice”, or any name describing the transaction, without the need to inform of such change the Revenue District Offices having jurisdiction over the place of business of such sales machines.
- Taxpayers that are using duly registered Computerized Accounting System (CAS) or Computerized Book of Accounts (CBA) with Accounting Records (AR) need to revisit their system to comply with the provisions of EOPT Act.

In order to provide ample time in reconfiguring machines and enhancement of CAS/CBA with AR, adjustments shall be undertaken on or before 31 December 2024. Any extension for the same must be approved by the concerned Regional Director or Assistant Commissioner of the Large Taxpayers Service which shall not be longer than six (6) months from 31 December 2024.

Non-conversion of ORs to “Invoice” within the period given

Issuing “Official Receipt” (with or without strikethrough) generated by CRM/POS machines, e-receipting, e-invoicing software, CAS or CBA with AR for sale of goods or service after 31 December 2024 or until the completion of machine reconfiguration/enhancement, whichever comes first, and issuing manual/loose leaf OR without converting them to “Invoice” for the sale of goods or service starting 27 April 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 invoice required under Section 6(A) hereof.

You may access the full version of this issuance through the BIR website.

For any inquiry or request for assistance, please feel free to contact anyone from our Tax Services group. You may also reach us through this link.