Uploaded by Herbert Escolano

Q & A ON SUPPLIER ISSUED INVOICE

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QUESTION & ANSWER
1.) When is the effectivity date of the IRR for Ease of Paying Taxes Act specially on the
IRR for invoicing requirements?
The IRR was posted on BIR website on April 12, 2024, IRR will take effect 15 days after
the posting on the official gazette or BIR website whichever comes first. So, the effectivity
date is April 27, 2024.
2.) I am a buyer, is it true that I cannot use our supplier’s Official Receipt to claim input
tax?
Yes, unless the supplier opted to convert their remaining unused official receipt as their
principal invoice (see question 4), EOPT Act mandates a single document for both sales
of goods and services. Hence, all references to Sales/Commercial Invoices or Official
Receipts shall now be referred to as “INVOICE” - BIR RR 3 2024 – Section 2(B)
Invoice as defined in RR 7 2024 – Section 2 is a written account evidencing the sale of
goods and/or services issued to customers in the ordinary course of trade or business.
This includes Sales Invoice, Commercial Invoice, Cash Invoice, Charge/Credit Invoice,
Service Invoice, or Miscellaneous Invoice. It is also referred to as a “principal invoice.”
Official Receipt, being now a supplementary document, is not valid proof to support the
claim of input taxes by the buyers of goods and/or services. RR 7 2024 – Section 2.2
The buyer can claim input taxes using a valid VAT Invoice.
3.) What are the two categories of Invoice?
a.) VAT Invoice – issued by a VAT supplier for sales of goods or services, whether cash
or on account. It shall be the basis of the output tax liability of the seller and the input
tax claim of the buyer or purchaser.
b.) Non-VAT Invoice - issued by a non-VAT supplier for sales of goods or services,
whether cash or on account. Sales are not subject to VAT. It shall be the basis of the
Percentage Tax liability of the seller.
4.) What will happen to the remaining unused manual or loose-leaf Official Receipts of
the supplier of services or lessor of properties?
The seller has two options for the unused Official Receipts as provided in RR 7 2024
Section 8.2
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Option 1 - Supplier may continue to use the remaining Official Receipts as
supplementary document.
– All unused Official Receipts may still be used ass supplementary document until fully
consumed, provided that the phrase “THIS DOCUMENT IS NOT VALID FOR CLAIM OF
INPUT TAX” is stamped on the face of the document upon the effectivity date of the
regulations. The Official Receipt, along with other equivalent documents such as
Collection Receipt, Acknowledgement Receipt and Payment Receipt are all the same,
serve as proof of payment that cash has been received or that payment has been
collected/made for goods and/or services.
Option 2 - Supplier may convert and use the remaining Official Receipts as Invoice
- For ease of doing business, supplier shall be allowed to strikethrough the word “Official
Receipt” (e.g Official Receipt) on the face of the manual and loose leaf printed receipt and
stamp “ Invoice”, “Cash Invoice”, “Charge Invoice”, “Credit Invoice", “Billing Invoice”,
“Service Invoice", or any name describing the transaction, and be issued as primary
invoice to its buyer/purchaser until December 31, 2024. This document shall be valid for
claim of input tax by the buyer/purchaser until December 31, 2024 only.
Official Receipt, whether stamped with “Invoice” or unstamped, issued after December 31,
2024, will be considered supplementary documents only and ineligible for input tax claims.
5.) What about for Cash Register machines (CRM) and Point-of-Sales (POS) Machines,
Electronic Invoicing Software and Computerized Accounting System (CAS)?
- Suppliers who uses CRM/POS/E-receipting/E-invoicing (e.g. machines used by the
cashier the department store/ grocery store/malls/online store and the like) may change
the word “Official Receipt (OR)” to “Invoice”, “Cash Invoice”, “Charge Invoice”, “Credit
Invoice”, “Billing Invoice", “Service Invoice", or any name describing the transactions,
without the need to notify the Revenue District Office(s) having jurisdiction over the place
of business of such sales machines, since the reconfiguration shall be considered as
minor system enhancement which shall not require the reaccreditation of the Permit to
Use of the supplier.
Documents issued by the CRM/POS/E-receipting/E-invoicing containing the word
“Official Receipt” beginning the effectivity of RR 7 – 2024 (April 27, 2024) shall not
be considered as valid for claim of input tax by the buyer/purchaser.
- Suppliers who use a duly registered Computerized Accounting System (CAS) need
to revisit their system to comply with the provision of the EOPT Act. Since the system
reconfiguration will have a direct effect on the financial aspect, it shall be considered as
major enhancement which will require taxpayer to update their system registration
following the existing policies and procedures of filing a new application. The previously
issued Acknowledgement Certificate (AC) or permit to Use shall be surrendered to the
RDO where the concerned supplier is registered. In order to provide ample time in
reconfiguring machines and systems, adjustments shall be undertaken on or before June
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30, 2024. Any extension due to enhancements of the system shall seek approval from the
concerned Regional Director or Assistant Commissioner of Large Taxpayers Service
which shall not be longer than six months from the effectivity of the regulations.
Issuance of “Official Receipt” for the sale of goods or services after June 30, 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) hereof subject to penalty of not less than 1,000.00 pesos but not more than
50,000.00 pesos and suffer imprisonment of not less than 2 years but not more than
4 years pursuant to Section 264(a) of the Tax Code
Reference: RR 7 2024 Section 8.3
6.) How to recognize a valid VAT Invoice that a buyer can use as proof for claiming
input tax?
RR 7 2024 SEC 3 - VAT registered persons are allowed to use the VAT as input tax credit
if the lacking information do not pertain to:
 Amount of vatable sales
 Amount of VAT
 Name and TIN of both buyer and seller
 Description or Nature of Goods or Services
 Date of Transaction
It is valid of course if the invoice is duly registered with the BIR, meaning, it has Authority
to Print (ATP) for manual and loose-leaf invoice or Acknowledgement Certificate (AC) for
Computerized Accounting System.
SAMPLE ATP, AC/CAS PERMIT & PTU
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7.) What will you do if the supplier gave you an invalid document to support your claim for
input taxes.
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