If you have been really busy running and growing your business or self-employment, you may not be aware of the new tax law, Republic Act No. 11976 – Ease of Paying Taxes (EOPT) Act, which changed the requirements on primary sales documents.
EOPT now says that all sellers of goods and services, including seller and leasing of properties, must issue Invoice.
The Bureau of Internal Revenue (BIR) issued Revenue Regulations (RR) No. 7-2024 to implement such new law. If you haven’t heard about RR 7-2024, you may refer to this article, How to Register Invoice per RR 7-2024.
But due to the short time given to comply, many were not aware of the new invoice requirements and were not able to comply within the deadlines set by the RR 7-2024 last May 27, 2024.
As such, the BIR reconsidered and extended the deadline by issuing Revenue Regulation (RR) No. 11-2024 last June 13, 2024.
RR 11-2024 amended, clarified and extended deadlines with regards to the compliance with the invoice, receipt and registration requirements stated in EOPT and RR 7-2024. You may read full text of RR 11-2024.
In addition, last June 14, 2024, the BIR also released Revenue Memorandum Circular No. 66-2024, which details alternative mode of submission of inventory list in compliance to the RR 7-2024. You may read full text of RMC 66-2024.
5 Key Amendments of RR 11-2024
Here are the key amendments, clarifications and extensions made by RR 11-2024 on invoice, receipt and registration requirements that you must know.
Clarifications on BIR Form 0605 – Annual Registration Fee
RR 11-2024 states that you do not have to replace or update your BIR Form 2303 – Certificate of Registration (COR) to remove the Tax Type – Registration Fee.
The BIR Form 2303 – COR keeps its validity even if it shows Registration Fee as tax type.
Upon effective date of EOPT last January 2024 and clarification made by RR 11-2024, filing and paying of BIR Form 0605 – Annual Registration Fee is no longer needed even if the Registration Fee is reflected in the Tax Type of your BIR Form 2303 – COR.
Only update BIR Form 2303 – COR if there are changes to be made on registration information, excluding Registration Fee.
Clarifications on Unused Official Receipts not used as Invoice
If there are unused official receipts that were not converted and used as invoice, it may still be used as supplementary document and not as primary document.
When you say supplementary, it is no longer valid evidence of sales, and for claiming of expenses and input tax, instead, it will be considered as proof of payment or collection.
Official receipts not converted to invoice will now be treated like collection receipt, acknowledgement receipt, and payment receipt.
As such, if still used beginning April 27, 2024 (effective date of RR 7-2024), you must put stamp in the face of the receipt with this phrases “This document is not valid for claim of input tax”.
The said unused official receipt not to be used as invoice can be used until fully consumed.
Clarifications on Unused Official Receipt to be used as Invoice
Per RR 11-2024, aside from unused Official Receipt, unused Billing Statement, Statement of Account and Statement of Charges were included in the options to convert and use as Invoice.
RR 11-2024 also emphasized that the required information such as quantity, unit cost and description or nature of services, must also be stamped in the face of the unused official receipt in order to be used as invoice, if not originally shown.
Another added clarification of RR 11-2024, Billing Invoice is now included in the Invoice option. Billing Invoice is also a primary sales document. Billing Invoice was not mentioned in RR 7-2024 as primary sales document, that’s why there was a bit confusion if billing invoice is primary sales document or supplementary prior to the release of RR 11-2024.
RR 11-2024 also amended the deadline until when you can use the unused official receipt as invoice. In RR 7-2024, it was originally mentioned that you can only use it until December 31, 2024, after which, you must apply and use new ATP Invoice.
But with RR 11-2024, this was changed. You can now unused official receipt to be used as invoice can be used until fully consumed. You may apply new ATP for Invoice once there are few booklets left of unused Official Receipt.
Another amendments made by RR 11-2024 from the earlier RR 7-2024 is the extension of the deadline for submission of “Inventory List of unused Official Receipt to be used as Invoice”. The deadline is extended to July 31, 2024.
In addition, per RMC 66-2024, to streamline the process, BIR provided that submission of inventory list of unused Official Receipt can be done via online or electronically, as follows:
a. via email through Taxpayer Registration Related Applications (TRRA) portal which is accessible in the BIR website under eServices. You may read full text of Annex A for the user guide.
b. via direct email to Compliance Section of the Revenue District Office (RDO). You may read full text of Annex B for the list of email address of RDO’s Compliance Section.
If online or electronic submission is not possible, you may submit physically via RDO.
Clarifications on Cash Register Machines (CRM), Point of Sales (POS) Machines, E-Receipting or Electronic Invoicing System (EIS) and Computerized Accounting Software (CAS) or Computerized Books of Accounts (CBA)
If using CRM, POS, E-Receipting or EIS, you may change and strikethrough the word Official Receipt/Billing Statement/Statement of Account/Statement of Charges and stamp “Invoice” or its equivalent. There’s no need to inform or reapply for accredited with the BIR since this change is considered minor system enhancements.
However, as for the CAS and CBA which may need revision to reflect changes made by EOPT Act, if there are enhancements that directly affect recording and financial reporting aspect, then it is considered major system enhancements. As such, there’s a need to surrender and update the existing Acknowledgement Certificate (AC) to the BIR. The deadline for this will be until December 31, 2024. If enhancement will take longer than December 31, 2024, there must be approval from BIR.
The renamed Invoice series will start within 30 days from the completion of the enhancement but not later than December 31, 2024. Any issued Official receipt using CRM, POS, E-Receipt, EIS, CAS, from April 27, 2024, until completion of the system enhancement, shall be valid for claiming input vat until December 31, 2024, or upon completion of the system enhancement.
Imposition of Penalties for Non-Compliance to the New Invoice Requirements
RR 11-2024 states that there will be penalties imposed for non-compliance, such as when you continue using Official Receipt as evidence of sales without complying to the requirements said above. If you do so, it will be considered a violation for failure to issue or non-issuance of invoice. The penalty will be from P1,000 up to P50,000 and imprisonment of not less than 2 years but not more than 4 years based on Section 264(a) of the Tax Code.
The effective date of RR 11-2024 will take at once upon publication in BIR website last June 13, 2024.
If you haven’t complied to the invoice requirement stated by RR 7-2024 and now RR 11-2024, it’s not yet too late to do so. If you need help, you may reach us via our Facebook page. You may like our page to be updated with new government rules that may affect your business or self-employment.
For easy recording of your invoice and receipt transactions, use MPM Accounting Software. You may try it for 30 days trial, click here. This software is locally developed, by yours truly with the aim of helping business owners and self-employed do their own bookkeeping and tax filing.
I hope this article helped you stay aware and updated to the changes in the rules on invoice requirements. Feel free to share your thoughts or questions in the comments section. Please help us spread this article by sharing it to others.
Hi, sorry i am confuse. Normally, for the services we provide, we issue a service receipt(which serve as billing or request for payment) and Official receipt (upon receiving payment). Could you please clarify the process, what we’ll issue for request for payment and upon collection? It would be a great help for me to resolve this confusion. thank you.
Hi, you may read this article RR 3-2024 https://mpm.ph/rr-3-2024-ease-of-paying-taxes-act/
What if the billing statement is converted into billing invoice, Is this valid for claiming input tax even if quoted to Billing statement is “this is not valid for claiming input tax”.
If you use billing statement as the new invoice, you need to also strike through the “this is not valid for claiming input tax” and put the information required in the invoice.
We are currently using CAS and already applied and just waiting for new acknowledgement certificate from BIR. However, can we issue the billing invoice where “this is not valid-” was removed and changed into “this is valid” even if we haven’t received the new BIR ACR?
it’s better to coordinate to your CAS provider about this matter.