2. 2024 Eopt Updates
2. 2024 Eopt Updates
• Documents issued by CRM/POS machines, e-receipting or electronic invoicing software, CAS or CBA with AR containing the
VALID FOR word "Official Receipt" from April 27, 2024 until the completion of machine/system reconfiguration/enhancement shall be
CLAIMING OF considered as valid for claiming of input tax by the buyer/purchaser until December 31, 2024 or until the completion of
INPUT TAX machine/system reconfiguration / enhancement, whichever comes first. Provided, that there is no missing information as
enumerated under Section 3(D)(3) of RR No. 7-2024 and the machine/system printed/generated "Official Receipt/Billing
Statement/Statement of Account/Statement of Charges" is converted by striking through the said term and stamping the
word "Invoice/Billing Invoice" on the document.
if a VAT-registered person or seller issues a duly registered VAT Invoice to
another VAT-registered person or buyer/purchaser with lacking information
required under Section 3(B) of these Regulations, the seller or issuer shall be
liable for non-compliance with the invoicing requirements. However, the VAT
amount shall still be allowed to be used as an input tax credit under Section
110 of the Tax Code, on the part of the purchaser or buyer, except if the
lacking information pertains to any of the following:
a. Amount of sales;
b. VAT amount;
c. Registered name and TIN as shown on the Bureau of
Internal Revenue (BIR) Certificate of Registration of both
purchaser or buyer and issuer or seller;
d. Description of goods or nature of services; and
e. Date of transaction.
Said notice shall be submitted within
Reported by submitting an The serial number of the renamed thirty (30) days from the completion
inventory of unused Official Invoice shall start by continuing the of machine/system
Receipts/Billing Statement / last series of the previously reconfiguration/enhancement or on
approved Official Receipt and shall December 31, 2023, whichever
Statement of Account / Statement
submit notice after the completion comes first.
of Charges indicating the number
of reconfiguration / enhancement,
of booklets and corresponding Any extension due to the
indicating the starting serial number reconfiguration/enhancements of
serial numbers on or before July
of the converted Invoice, to the system must be approved by the
31, 2024, to the RDO/LT Office/LT
RDO/LT Office/LT Division where the concerned Regional Director or
Division where the Head Office or Assistant Commissioner of the Large
machines are registered, in duplicate
Branch Office is registered, in copies. Taxpayers Service which shall not be
duplicate copies. longer than six (6) months from
December 31, 2024.
• Issuing manual/loose leaf "Official Receipt" without converting them to "Invoice"
for the sale of goods or service starting April 27, 2024
• Such failure is subject to penalty of not less than One Thousand Pesos (Php
1,000.000 but not more than Fifty Thousand Pesos (Php 50,000.00) and suffer
imprisonment of not less than two (2) years but not more than four (4) years
pursuant to Section 264(a) of the Tax Code.
Clarification on the Invoicing Requirements
Provided Under Revenue Regulations (RR) No.
7-2024, as Amended by RR No. 11-2024
A VAT-registered person shall issue a A Non-VAT-registered person shall issue a
duly registered Non-VAT Invoice for every
duly registered VAT Invoice for every
sale, barter, exchange or lease of goods or
sale, barter, exchange or lease of goods properties, and for every sale, barter or
or properties, and for every sale, barter exchange of services valued at Five Hundred
or exchange of services regardless of the Pesos (Php 500.00) or more. However, if a
buyer requests for an Invoice, the seller must
amount of the transaction.
issue the same regardless of the amount of
transaction.
a. For VAT-registered sellers, the issuance of VAT Invoice for each sale transaction
is required, regardless of the amount of transaction.
b. For Non-VAT registered sellers, an invoice shall be issued in the following cases:
• Invoice - Issued for both sales of goods or services rendered • Invoice/Sales Invoice issued for cash and/or credit sales
• Sales Invoice - General purpose Invoice for any sales transaction • Cash Invoice issued for cash sales and Credit/Charge Invoice issued
• Cash Invoice - Used for cash sales or specifically for sales where immediate for sales on account/credit sales
payment is received
• Invoice/Sales Invoice for sales of goods and Service Invoice for sales
• Charge/Credit Invoice - Issued for sales on credit, where payment is
of service
expected at a later date
• Service Invoice - Used for transactions where a service is provided • Sales Invoice for primary sales transaction and Miscellaneous Invoice
• Billing Invoice - A document to bill charges similar to Charge Invoice and for other income
contains other information similar to a statement of account, billing • Invoice/Billing Invoice issued to bill customers.
statement, summarizing charges for a specific transaction
• Commercial Invoice - A document used by exporter for export transactions Taxpayers may have its own choice of using more than one type of
• Miscellaneous Invoice - Issued for other income received by the seller Invoice. However, such choice should consider the transactions that will
be issued said lnvoice/s.
A: No. Sellers cannot issue an invoice upon receipt of payment. However,
A: Yes. An Invoice is a document evidencing sale of goods or service.
an Official Receipt or Payment Receipt or Acknowledgement Receipt may
However, such Invoice may contain an information acknowledging the
be issued upon subsequent collection or receipt of payment.
receipt of payment for the said sales transaction.
A: Service providers who billed their customers shall now issue a Billing Invoice upon
billing instead of Billing Statement or Statement of Account. The Billing Invoice should
contain the required information provided under RR No. 7-2024, as amended, including
the quantity, unit cost and description or nature of service pursuant to Sec. 237 of the
Tax Code.
Taxpayers shifting from Official Receipt to Sales Invoice For those opting to continue using Official Receipt as
or its equivalent Invoice replacement shall apply for a supplementary document, it shall continue the last
new ATP Invoice. approved serial number of its Official Receipt when
If the taxpayer is using different types of Invoices, each applying for subsequent ATP for Official Receipt as
type or name of Invoice shall have a separate set of serial supplementary document.
numbers starting from one (1) (e.g. 0000001) or any
number (e.g. 5000001) or taxpayer may add prefix or
suffix to make such number distinct.
[
]
A: Yes. All unused manual and loose leaf Official Receipts to be converted as
A: Taxpayers using CRM / POS / Invoice shall be reported to the BIR by submitting an Inventory
e-Receipting / Report(suggested format - Annex C) of unused Official Receipts (in duplicate
e-lnvoicing systems can now copies), indicating the number of booklets and the serial numbers of the
replace "Official Receipt" with a unused Official Receipts converted to Invoice.
more descriptive term for their Taxpayers using CRM/POS machines/E-receipting (CAS/CBA with e-
Invoices without the need for receipting) or e-invoicing software that renamed the Official Receipts being
approval of the Revenue District issued to Invoice shall be reported by submitting a Notice on the Renaming
Office. of Machine/System Generated Official Receipt to Invoice (suggested format -
Annex D) indicating the starting serial number of the converted Invoice and
the start date when such serial number was/will be issued.
Provided, that the serial number of the renamed Invoice shall start by
continuing the series from the last issued Official Receipt. The seller shall Taxpayers who have already submitted the inventory report using Annex D
submit a Notice in two (2) copies (both original), indicating the starting serial of RMO No. 12-2013 or Letter Notice prior to the publication date of this
number of the converted Invoice and the start date when such serial Circular on the BIR official website are no longer required to resubmit the
number was/will be issued. inventory report using the format outlined in Annex C or D of this Circular.
Such Notice shall be submitted to the RDO/L T Office/LT Division where the
sales machines are registered.
A: Taxpayers requesting for an extension to enhance their system shall
notify the concerned RDO/LT Office/LT Division through the Compliance A VAT-registered person with mixed transactions may issue a single or
Section/concerned LT Office/Division, where they are registered, for separate Invoice for its Vatable, VAT-Exempt, and Zero-Rated sales.
approval of the concerned Regional Director or Assistant Commissioner
Should the said seller opt to have only one Invoice, the VAT amount and
of the Large Taxpayers Service, by submitting a Letter Request before
sales amount must be broken down as to Vatable Sales, VAT-Exempt
December 31, 2024 stating the reason or justification for the request for
Sales, Zero-Rated Sales and the corresponding amount for each type of
extension, the target date of the completion of enhancement, email
sale should be indicated in the Invoice.
address, and contact details of the contact person.
Sample:
The RDO / LT Office / LT Division shall act on the request within three
(3) working days from receipt of the letter from the taxpayer and VATable Sales P200,000.00
recommend for its approval / disapproval by the Regional Director or VAT 24,000.00
Assistant Commissioner. VAT-Exempt Sales 50,000.00
Zero-Rated Sales 26,000.00
The Regional Director or Assistant Commissioner shall act on the Provided, that if the seller opt to issue separate Invoice for each type of
request within three (3) working days from receipt of the sale, the word "VAT-Exempt Sale" or "Zero-Rated Sale" shall be written or
recommendation of the RDO. prominently printed on each Invoice.
ISSUING AN OFFICIAL RECEIPT (WHETHER STAMPED WITH ISSUING AN OFFICIAL RECEIPT, PAYMENT RECEIPT, COLLECTION
"INVOICE" OR UNSTAMPED) GENERATED BY CRM/POS, E- RECEIPT, BILLING STATEMENT OR STATEMENT OF ACCOUNT ONLY
RECEIPTING OR ELECTRONIC INVOICING SOFTWARE AND CAS/CBA WITHOUT THE CORRESPONDING INVOICE OR BILLING INVOICE
WITH AR FOR THE SALE OF GOODS AND SERVICES AFTER UPON SALE OF GOODS OR SERVICES
DECEMBER 31, 2024 OR UNTIL THE COMPLETION OF
MACHINE/SYSTEM RECONFIGURATION/ENHANCEMENT,
WHICHEVER COMES FIRST, AND ISSUING OF MANUAL AND LOOSE Official Receipt, Payment Receipt, Collection Receipt, Billing
LEAF OFFICIAL RECEIPT (UNSTAMPED) AFTER APRIL 27, 2024 Statement or Statement of Account under RR No. 7-2024 are
supplementary documents. Hence, when issued upon sale of goods
The issuance of such "Official Receipt" for every sale of goods or and services, it is not considered as evidence of sales of goods or
services after the prescribed period shall not be considered as services and shall be tantamount to failure to issue or non-issuance
evidence of sales of goods or services and shall be tantamount to of Invoice required under Section 6(A) of RR No.7-2024. Such is
failure to issue or non-issuance of Invoice required under Section subject to penalty of not less than One Thousand Pesos
6(A) of RR No. 7-2024, which is subject to penalty of not less than (Php1,000.00) but not more than Fifty Thousand Pesos
One Thousand Pesos (Php1,000.00) but not more than Fifty (Php50,000.00) and imprisonment for not less than two (2) years
Thousand Pesos (Php50,000.00) and imprisonment for not less but not more than four (4) years pursuant to Section 264(a) of the
than two (2) years but not more than four (4) year pursuant to Tax Code.
Section 264(a) of the Tax Code.
VAT-REGISTERED TAXPAYER ISSUING AN INVOICE WITH NON-VAT SELLER ERRONEOUSLY ISSUED A VAT INVOICE
INCOMPLETE INFORMATION REQUIRED UNDER SECTION 3(8) AND
A seller who is not VAT-registered and issued a VAT Invoice shall be
SECTION 6(8) OF RR NO. 7- 2024, AS AMENDED
liable to following, in addition to its Percentage Tax liability:
If a VAT-registered seller issues a duly registered VAT Invoice to a
VAT-registered buyer/purchaser with lacking information required
under Section 3(8) and Section 6(8) of RR No. 7-2024, the seller or 1. VAT imposed under Section 106 or 108 of the Tax Code,
issuer shall be liable for non-compliance with the invoicing without the benefit of any input tax credit; and
requirements. 2. A fifty percent (50%) surcharge under Sec. 248(8) of the Tax
Code.
However, the VAT amount shall still be allowed to be used as an
The VAT amount can be recognized as an input tax credit on the
input tax credit under Section 110 of the Tax Code, on the part of
part of the VAT-registered purchaser under Section 110 of the Tax
the VAT-registered purchaser or buyer, except if the lacking
Code, as amended, if all of the following information are present:
information pertains to any of the following:
In case of recovery of uncollected receivables, the output VAT pertaining thereto shall be
added to the output VAT of the taxpayer during the period of recovery.”
NOTE: “after the lapse of the agreed upon period to pay” = if there is a written promise to pay at a certain
period but such period has passed and yet the customer or buyer did not pay.
What are the conditions before a seller can credit the VAT paid
on the uncollected receivables?
1. Sale on account or on credit has taken place after the effectivity of RR 03- 2024 (April
27, 2024);
2.There’s a written agreement on the period to pay the receivable, i.e. credit term is
indicated on the invoice, which agreed period, extended or not, has lapsed
3.VAT is separately shown on the invoice
4.Sale is specifically reported in the SLS (no various sales)
5.The seller declared in the 2550Q the corresponding output VAT indicated in the invoice
within the period prescribed under existing rules
6.The VAT component of the uncollected receivable was not claimed as a deduction from
gross income (i.e. bad debt) pursuant to Sec. 34(E) of the Tax Code
Only the seller can claim output VAT credit on uncollected receivable on sales on credit
that happened upon the effective date of RR 3-2024
The introduction of output VAT credit do not affect the rules on deductibility of bad debts
expense for income tax purposes set by RR 25-2002. The mere lapse of the agreed upon
period to pay with or without any effort from the seller to collect the sales on account
shall entitle the seller to output VAT credit subject to the conditions set.
Availing the output VAT credit on uncollected receivable is only an option for the seller, it is
not automatic, especially if the likelihood of the collectability is high This will avoid the
reversal of output VAT credit in the eventual collection of the receivable.
Sec. 110(D) mandates that the claim shall be on the next quarter, after the lapse of the
agreed upon period to pay.
• The customer / buyer must be properly identified in the Summary List of Sales in the
quarter the sale was made. If the seller consolidates all sales into a single entry titled
"various", the lumping shall be considered invalid compliance with the requisites, and
the output VAT cannot be used or allowed as VAT credit should the transaction
remain uncollected after the lapse of the agreed period to pay.
1.Those tagged as CBL
2.Those with filed complaints at DOJ under RAFT and
RATE
3.Other taxpayers that may be identified by the CIR
• If the goods were returned during the agreed upon
period to pay and the output VAT is not yet paid, a
deduction from gross sales in the quarter where the
goods were returned is allowed.
• The output VAT credit shall only apply to sale of goods and/or services
on account that transpired upon the effectivity of RR 3-2024.
Circularizing the availability of the revised BIR
Form No. 2550Q [Quarterly Value-Added Tax
(VAT) Return]
April 2024
Output VAT on
Uncollected
Receivables
Output VAT on
Input VAT on Unpaid
Recovered
Payables
Uncollected
Receivables
Previously Deducted
• For eBIR Forms filers - file using the existing version in the Offline eBIR Forms package v.7.9.4.2
and pay the VAT payable, if any, through online payment or manual payment.
• In cases where the eFPS or eBIRForms filers have amounts to be indicated in any of the items 35,
36, 55 and 58 mentioned, they shall use the manual form to file their Value-Added Tax. They
shall download and print the PDF version of the revised BIR Form No. 2550Q, and must fill out
all the applicable fields; otherwise, penalties under Sec. 250 of the Tax Code, as amended, shall
be imposed. If there is a VAT payable, payment shall be made through any AAB or thru a RCO
under any RDO.
Clarifying the Provisions of Republic Act No.
11976 otherwise known as “The Ease of
Paying Taxes Act”, Applicable to the Power
Industry
• For sale of services, including the sale of power, gross sales of DU’s and EC’s shall exclude the value added tax
and those amounts earmarked for payment to third party or received as reimbursement for payment on behalf
of another which do not redound to the benefit of the seller as provided under relevant laws, rules and
regulations
• The DU’s and EC’s shall issue invoice to the customers, which shall include the sale and transmission of electricity
and ancillary services, including the VAT thereon of the Generation Companies and Transmission Companies
However, DU’s and EC’s shall not claim any input tax from these. The proper claimant shall be the
customers engaged in business on the invoice to be issued by the DU’s and EC’s
• The amount invoiced by the GenCo’s and Transmission Companies, which was included in the invoice issued by
the DU’s and EC’s to the customers, including the VAT charges thereon, shall be the basis of income tax and VAT
liabilities of the GenCos ang Transmission Companies
Pass through charges of the RES are the transmission and
distribution charges.
The RES shall not claim any input tax on the pass through
charges invoiced to the customers.
The following mandated government charges shall NOT be subject to output tax
and creditable withholding tax on VAT and Income:
1. GenCos and TransCos shall submit (hard and soft copy), to the
concerned RDO / LT offices, on or before September 30, 2024, an
inventory of the outstanding deferred VAT prior to April 27, 2024 from
DUs / ECs and others. Please refer to Annex B below:
2. DUs and ECs shall remit the deferred VAT, as collected, on behalf of each
GenCos and Transmission Companies, using BIR Form No. 0605. The TIN
of the GenCos and TransCos shall be clearly indicated in the BIR Form No.
0605. Mark "X” the box for “Others (Specify)” and indicate that the
payment is for "DEFERRED VAT - RMC NO. ____”.