Let’s Talk Tax

On June 13, the BIR released Revenue Regulations (RR) No. 11-2024, amending the transitory provisions of RR No. 7-2024 and extending the statutory deadlines for compliance with the new Invoicing requirements under the Ease of Paying Taxes (EoPT) Act. RR No. 7-2024 became a key regulation in implementing EoPT, serving as a framework to guide taxpayers in navigating the new Invoicing requirements. While the implementation of EoPT may be challenging, the BIR remains dauntless and patient in addressing taxpayer concerns by releasing timely regulations.

One of the major changes involves paragraph 2.2 of Sec. 8 of RR No. 7-2024, where taxpayers are allowed not only to convert Official Receipts into Invoices but are also to convert Billing Statements/Statements of Account/Statements of Charges into Billing Invoices. Under RR No. 7-2024, taxpayers were only allowed to use these converted Invoices or Billing Invoices until Dec. 31, 2024 only. This was changed in RR No. 11-2024, where taxpayers may now use the same until fully consumed. The additional requirement, however, is that these converted Invoices or Billing Invoices must contain the required information under Sec. 6(B) of RR No. 7-2024, including the quantity, unit cost, and description or nature of the service. If the required information is not readily available in the converted Invoice or Billing Invoice, these may be stamped to comply with these requirements.

Adding to the change brought forth by RR No. 11-2024 in paragraph 2.2 of Sec. 8 of RR No. 7-2024 as mentioned above, the converted Invoices or Billing Invoices may be considered valid for claiming input tax and proof of both sales transactions and payments of the same time from April 27, 2024, until they are fully consumed, provided that there is no missing information as enumerated under Sec. 3(D)(3) of RR No. 7-2024. Any manual or loose leaf “Official Receipt” issued without a stamped “Invoice” will be considered a supplementary document, ineligible for input tax claims.

The stamping of converted Invoices or Billing Invoices does not require approval from the Revenue District Offices/Large Tax Offices/Large Tax Divisions. Taxpayers are reminded that they should still obtain newly printed invoices with an Authorization to Print (ATP) before fully consuming the converted Invoice or Billing Invoice.

Taxpayers are still required to submit 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 July 31.

For taxpayers looking to reconfigure their Computerized Accounting System (CAS)/Computerized Books of Account (CBA) with Accounting Records (AR), the BIR extended the deadline for compliance from June 30 to Dec. 31, 2024. This may be extended for a further six months, subject to approval from the Regional Director or Assistant Commissioner of the Large Taxpayers Service. To recall, the BIR treated the modification of CAS/CBA with AR to comply with EoPT as a major enhancement as it would have a direct effect on the financial aspects.

The BIR also acknowledges and recognizes the challenge of modifying the documents issued by Cash Register Machines (CRM)/Point-Of-Sale (PoS) machines, e-receipting or electronic invoicing software, CAS/CBA with AR, by allowing the use of the invoices bearing the word “Official Receipt” from April 27 until the completion of machine/system reconfiguration/enhancement. These invoices issued while the software is being reconfigured may be considered valid for claiming input tax by the buyer or purchaser until Dec. 31, 2024 or until the completion of machine/system reconfiguration/enhancement, whichever comes first. The BIR added a requirement that the use of these mentioned invoices should have complete information as required under Section 3(D)(3) of RR No. 7-2024.

For CRM/PoS Machines, e-receipting or electronic invoicing software, the change of the word “Official Receipt” to “Invoice,” “Cash Invoice,” “Charge Invoice,” “Credit Invoice,” “Billing Invoice,” or any name describing the transaction, the change is still treated as a minor change or enhancement without the need to report the change to the Revenue District Office(s) having jurisdiction over the place of business of such sales machines.

However, after Dec. 31, 2024 or once the machine/system reconfiguration/enhancement has been completed, the issued invoices will not be considered evidence of sales of goods or services and is tantamount to failure to issue or non-issuance of invoices. The same is true for the issuance of manual/loose-leaf “Official Receipts” without converting them to “Invoices” for the sale of goods or services starting April 27.

To recall, the penalty mentioned by the BIR is the penalty of not less than P1,000 but not more than P50,000 and imprisonment of not less than two years but not more than four years pursuant to Sec. 264(a) of the Tax Code.

With these changes brought forth by RR No. 11-2024, the BIR hopes to have answered the concerns of taxpayers over the recent regulations for EoPT. The BIR’s efforts in reaching out to taxpayers should be commended. From holding town halls, lecture series, and the like not only for tax practitioners but for taxpayers as well, to issuing multiple regulations to address any questions from the public, the BIR has been working tirelessly hand in hand to deliver the future envisioned by the EoPT Act, which is “to provide a healthy environment for the tax paying public that protects and safeguards taxpayer rights and welfare, as well as assures the fair treatment of taxpayers.”

Let’s Talk Tax is a weekly newspaper column of P&A Grant Thornton that aims to keep the public informed of various developments in taxation. This article is not intended to be a substitute for competent professional advice.


John Patrick L. Paumig is a manager from the Tax Advisory & Compliance division of P&A Grant Thornton, the Philippine member firm of Grant Thornton International Ltd.