BIR Issues Revenue Regulations No. 11-2024 Amending Transitory Provisions on Deadlines for Compliance with the Invoicing Requirements

The Bureau of Internal Revenue (“BIR”) issued Revenue Regulations (“RR”) No. 11-2024 to amend Section 8 or the transitory provisions of RR No. 07-2024. Accordingly, the following changes were made:

1. The old Section 8 already allows taxpayers to convert and use remaining Official Receipts as Invoice. RR No. 11-2024 expands this provision by also allowing taxpayers to convert remaining Billing Statement/Statement of Account/Statement of Charges into Billing Invoice so long as the following are complied with:

1. The taxpayer must (i) strikethrough the word “Billing Statement,” “Statement of Account,” “Statement of Charges” on the face of the manual and loose leaf printed receipt, (ii) stamp “Invoice,” “Cash Invoice,” “Charge Invoice,” “Credit Invoice,” “Billing Invoice,” “Service Invoice,” or any name describing the transaction, and (iii) issue the same as primary invoice to its buyer/purchaser until fully consumed; and
2. The converted “Billing Statement/Statement of Account/Statement of Charges” must 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 Section 237 of the National Internal Revenue Code, as amended (“Tax Code”). Such information and other required information may also be stamped if not originally indicated in the old Billing Statement/Statement of Account/Statement of Charges to comply with these requirements. 

2. The old Section 8 provided that converted Official Receipts shall only be valid for claim of input tax by the buyer/purchaser and can serve as proof of both sales transaction and payment for the period issued from 22 January 2024 to 31 December 2024; thereafter, any Official Receipts, whether stamped or unstamped, issued after 31 December 2024, will be considered supplementary documents ineligible for input tax claims. RR No. 11-2024 amended this provision by providing that converted Official Receipts and Billing Statement/Statement of Account/Statement of Charges (i) shall be considered valid for claiming of input tax by the buyer/purchaser and (ii) can serve as proof of both sales transaction and payment for the period issued from 27 April 2024 until they are fully consumed. 

3. Effective 27 April 2024, any manual/loose leaf “Official Receipts” issued without a stamped “Invoice” will be considered supplementary documents and ineligible for input tax claims. 

4. Converted Official Receipts/Billing Statement/Statement of Account/Statement of Charges shall be reported by submitting an inventory of unused Official Receipts/Billing Statement/Statement of Account/Statement of Charges indicating the number of booklets and corresponding serial numbers on or before 31 July 2024, to the Revenue District Office (“RDO”)/Large Taxpayers (“LT”) Office/LT Division where the Head Office or Branch Office is registered, in duplicate copies. This effectively extended the deadline provided in RR No. 7-2024.

5. As already provided in the old Section 8, taxpayers that are using duly registered Computerized Accounting System (“CAS”) or Computerized Books of Accounts (“CBA”) with Accounting Records (“AR”) need to update their system registration to comply with the provisions of the Ease of Paying Taxes Act by surrendering previously issued Acknowledgement Certificate ”or Permit to Use to the RDO where the concerned taxpayer is registered and obtaining a new one. RR No. 11-2024 prescribes that 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. This effectively extended the deadline provided in RR No. 7-2024 to on or before 30 June 2024. Any extension due to the reconfiguration/enhancements of system 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.

6. The serial number of the renamed Invoice to be issued by Cash Register Machine (“CRM”) or Point-of-Sales (“POS”), e-receipting or electronic invoicing software, CAS or CBA with AR shall start by continuing the last series of the previously approved Official Receipt. 

7. Notice shall be submitted after the completion of reconfiguration/enhancement, indicating the starting serial number of the converted Invoice, to the RDO/LT Office/LT Division where the machines are registered, in duplicate copies, within thirty (30) days from the completion of machine/system reconfiguration/enhancement or on 31 December 2024, whichever comes first. The receiving Branch RDO shall transmit the original copy to the Head Office RDO. 

8. Documents issued by CRM/POS machines, e-receipting or electronic invoicing software, CAS or CBA with AR containing the word “Official Receipt” from 27 April 2024 until the completion of machine/system reconfiguration/enhancement shall be considered as valid for claiming of input tax by the buyer/purchaser until 31 December 2024 or until the completion of machine/system reconfiguration/enhancement, whichever comes first, so long as: 

1. There is no missing information as enumerated under Section 3(D)(3) of RR No. 7-2024; and 
2. The machine/system printed/generated “Official Receipt/Billing Statement/Statement of Account/Statement of Charges” is converted by striking through the term “Official Receipt/Billing Statement/Statement of Account/Statement of Charges” and stamping the word “Invoice/Billing Invoice” on the document. 

9. Issuing “Official Receipt” (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 31 December 2024 or until the completion of machine/system reconfiguration/enhancement, whichever comes first, and issuing manual/loose leaf “Official Receipt” 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) of RR No. 11-2024. Such failure is subject to penalty of no less than PHP1,000.00 but not more than PHP50,000.00 and imprisonment of not less than two (2) years but not more than four (4) years pursuant to Section 264(a) of the Tax Code.