[Ask the Tax Whiz] Ease of Paying Taxes law: What’s new with invoicing requirements?  

I am a taxpayer who still has unused manual and/or looseleaf official receipts. Can I still use them? Or are invoices the only accepted valid proof to support claims of input taxes?

Under the EOPT law, if you have unused official receipts (ORs), you may still use them as supplementary documents, provided that it is stamped with the phrase, “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.” Furthermore, you can also convert the unused ORs into invoices by striking through the word “OR” and replacing it by stamping “Invoice.” This would then be considered as the primary invoice and is valid for the claim of input tax until December 31, 2024.  

If I opt to convert my ORs into invoices, do we need to report these changes to the BIR? 

Yes, you will need to submit an inventory of unused OR to the BIR, indicating the number of booklets and corresponding serial numbers in duplicate original copies until July 31, 2024. The proposed regulation amending Revenue Regulation No. 7-2024 is under review. 

Note that the stamping of ORs does not require approval from BIR.

Are there any changes to the required information regarding the invoicing requirements for the issuance of invoices? 

Another key change introduced by the EOPT law is the removal of the “Business Style” as a required information in an invoice for claiming input tax. Previously, the lack of this information could lead to the disallowance of VAT credit or refund claims due to non-compliance with invoicing requirements.

Revenue Regulation No. 7-2024 specifies that invoices must be issued for transactions amounting to P500 or more.  However, sellers are still required to issue invoices upon the buyer’s request, regardless of the transaction amount.

If a VAT-registered individual fails to include complete information on the invoice, they will be held liable for non-compliance. However, the purchaser can still claim the VAT as an input tax credit if the following details are accurately provided:

• Amount of sales
• Amount of VAT
• Name and TIN of both the purchaser and issuer/seller
• Description of goods or nature of services
• Date of transaction

What about the ORs being issued by Cash Register Machines (CRM), Point-of-Sale (POS) systems, E-receipting, or any Electronic Invoicing Software?

For those who are using CRMs, POS systems, and e-receipting or electronic invoicing software, the term “Official Receipt” can be changed to “Invoice.” This adjustment is regarded as a minor system enhancement by the BIR, so taxpayers generally do not need to inform the BIR, accredit their sales software, or apply for a new Permit to Use (PTU).

Are there any additional guidelines in the new issuances that I, as a taxpayer, should consider, especially if we are using a Computerized Accounting System (CAS) or Computerized Books of Accounts (CBA)?

Under RR 7-2024, changes in CAS or CBA constitute a major system enhancement as they will not only affect the invoicing system but also the timing of reporting output VAT on the sale of services. Therefore, taxpayers are required to return the previously issued Acknowledgement Certificate (AC) or PTU and request a new AC. The accompanying attachment of the AC should list all branches (if applicable) utilizing the system, along with the invoice series assigned to each branch. 

Since the system reconfiguration is a major enhancement, taxpayers have until June 30, 2024, to implement the necessary changes. If the enhancements cannot be completed by the stated deadline, you may formally request an extension from the respective Regional Director or Assistant Commissioner for Large Taxpayers. This extension shall not exceed six months from the effective date of the regulation.  

For expert advice on the changes in  invoicing requirements under EOPT law, consult ACG. – Rappler.com