Issues in Invoicing During ECQ
Due to the strict implementation of the Enhanced Community Quarantine (ECQ), many taxpayers experience difficulties when it comes to the issuance of receipts/invoices to their customers.
Manual receipts with Authority to Print (ATP) and computer-generated receipts with duly approved Permit to Use (PTU) or Acknowledgment Certificate are not accessible due the closure of most business establishments. Sending or mailing of the actual receipts/invoices through postal services is currently impossible due to non-observance of standard operating hours. Also, some taxpayers have their ATP expired during ECQ.
Work-around Invoicing Procedures During ECQ
BIR has issued Revenue Memorandum Circular (RMC) 47-2020 to address the above concerns of the taxpayers. Under the RMC, the taxpayers may adopt or use any of the following measures to ensure invoicing compliance even during the ECQ:
- BIR Printed Receipts/Invoices (BPR/BPI) pursuant to RMC No. 28-2019, as amended;
- Scanned Copy of Receipt/Invoice with ATP, which is to be electronically transmitted electronically in file format prescribed in the Circular (JPEG, PDF, or any equivalent format to the customer);
- Computer-aided Receipt/Invoice in Excel format not covered by an ATP, which is to be transmitted electronically in file format prescribed in the Circular;
- Supplementary Receipt/Invoices to be issued in lieu of the Principal Receipt/Invoice;
- Receipt/Invoice using existing Computer Accounting System (CAS) or its Components with approved PTU or Acknowledgement Certificate; however, the said receipt/invoice is being sent electronically in file format prescribed in the Circular to the customer; or,
- Receipt/Invoice generated from a newly developed receipting/invoicing software or CAS with duly approved PTU or Acknowledgement Certificate, which was used temporarily generate/issue the receipts/invoices and the receipt/invoice is being sent electronically in file format prescribed in the Circular to the customer.
Guidelines and Conditions in the Adoption of Work-around Procedures
To effectively use any of the above work-around invoicing procedures during ECQ, the following guidelines should be strictly observed by the concerned taxpayers:
- A formal letter must be submitted to BIR on the implemented procedures within 3 days from effectivity of Circular indicating the following information:
- Name of Taxpayer
- Registered Address
- Tax Identification Number (TIN)
- Temporary measures to be used in invoicing during ECQ and the serial numbers of the invoices/receipts to be issued
- Statement that taxpayer is amenable to a post-verification of the reported sales during ECQ , as ordered by the Commissioner
- Signature of taxpayer or authorized representative and designation.
Letter must be sent through email to the following:
|Type of Taxpayer||Department||E-mail Address|
|Non-large Taxpayer||Client Support Service (CSS)
Attention: Taxpayer Service Programs and Monitoring Division (TSPMD)
Large Taxpayers (LTs)
|Large Taxpayers Assistance Division (LTAD)
– for LTs registered under RDO 116, 125 and 126
|Excise Large Taxpayers Regulatory Division (ELTRD) – for LTs registered under RDO 121 and firstname.lastname@example.org|
|LT District Office Cebu
– for LTs registered under RDO 123
|LT District Office Davao
– for LTs registered under RDO 127
|email@example.com and/or firstname.lastname@example.org|
2. Upon lifting of ECQ, taxpayers must provide or issue the duly authorized receipts/invoices to their customers to cover all the sales issued with temporary receipts/invoices in accordance with the Circular and these are to be prioritized over the current transactions. The actual date of transaction should be indicated in the authorized manual receipt/invoices to be issued and a copy of the temporary receipt should be attached for audit purposes.
For those using CAS, where the system automatically indicates the date of transaction, the actual date of transaction should be indicated in the face of the receipt/invoice in any manner feasible. Consequently, these are not to be considered out-of-period receipts/invoices.
3. A Summary of Temporary Receipt/Invoices Issued (format in the Annex “A” of the RMC) should be submitted to the BIR Offices in item 1 within 90 days from the date of lifting of ECQ.