Taxpayers’ clamor heeded: It’s a YES!

TOP OF MIND - Renier Aries Razon - The Philippine Star

Maintaining the equilibrium between the state and its taxpayers, the Bureau of Internal Revenue (BIR) revisited some policies and business processes after heeding the clamor of some taxpayers. On 30 June 2022, the BIR issued Revenue Regulations (RR) 6-2022 relative to the removal of the five-year validity period on all manual and system-generated receipts and invoices in line with Republic Act (RA) 11032, or the Ease of Doing Business and Efficient Government Service Delivery Act of 2018, to improve, streamline, and reduce financial burden of taxpayers.

As a recap, the BIR earlier regulated all invoices and receipts printing by setting a five-year validity period on Authority to Print (ATP). After the lapse, taxpayers should be aware of incurring additional costs in printing new sets of manual receipts and invoices despite the unused forms’ availability.  As required, all unused or unissued receipts and invoices, together with an inventory list of the forms, must be surrendered to the BIR for destruction and non-compliance will subject the taxpayers to a penalty. The same regulation was extended to system-generated receipts or invoices issued from cash register machines (CRMs), point-of-sale (POS) machines, and other sales receipting system software. Taxpayers will reapply for renewal of their Permit to Use (PTU), which to some is an additional burden. In response to these concerns, the BIR issued RR 6-2022, and on 30 August 2022, Revenue Memorandum Circular (RMC) 123-2022 to clarify the provisions of the said Regulations relative to the removal of the five-year validity.

RMC 123-2022 states that RR 6-2022 took effect on 16 July 2022, fifteen (15) days from the date of its publication on 1 July 2022. It states that all taxpayers who are or will be using Principal and Supplementary Receipts or Invoices shall be covered by the said Regulations or taxpayers with or who will apply for any of the following: a. ATP; b. Registration of Computerized Accounting System (CAS)/Computerized Books of Accounts (CBA) and/or its Components; and c. PTU CRM/POS Machines and other Sales Receipting Software.  As a result, all receipts or invoices which have expired on or before 15 July 2022 are no longer valid. If the date of issuance of ATP is on or before 16 July 2017 and “Valid Until” as reflected in ATP/Receipts/Invoices on or before 15 July 2022, they cannot be issued anymore. Meanwhile, if the date of issuance of ATP is on 17 July 2017 onwards and “Valid Until” as reflected in ATP/Receipts/Invoices 16 July 2022 onwards, they can still be issued until fully exhausted.

RMC 123-2022 further provides that pursuant to Revenue Memorandum Order (RMO) 12-2013, all unused and expired forms dated on or before 15 July 2022 shall be surrendered, together with an inventory list, to the BIR, on or before the tenth (10th) day after the validity period for destruction. The phrase, “THIS INVOICE/RECEIPT SHALL BE VALID FOR FIVE (5) YEARS FROM THE DATE OF THE ATP” and the “Validity Period” reflected at the footer of the printed forms shall be disregarded.

Yielding no penalty, the RR provides no sanction for late application for taxpayers with ATP expiring on or before 15 July 2022 who failed to apply for subsequent ATP not later than the sixty (60)–day mandatory period prior to expiration. However, taxpayers who used or will use unregistered forms that expired prior to 15 July 2022, shall be subjected to penalty of  P20,000 and P50,000 for the first and second offense respectively.

Moreover, for all CRM/POS and other sales receipting software accreditation, the RMC clarifies that the phrases “THIS INVOICE/RECEIPT SHALL BE VALID FOR FIVE (5) YEARS FROM THE DATE OF THE PERMIT TO USE” and the “Valid Until (mm/dd/yyyy)” reflected on the footer of generated forms shall no longer be required. Similarly, for CAS registration and/or its components, the phrase appearing on the generated forms, “THIS INVOICE/RECEIPT SHALL BE VALID FOR FIVE (5) YEARS FROM THE DATE OF THE ACKNOWLEDGMENT CERTIFICATE,” likewise shall no longer be required.

Eventually, taxpayer-users with valid registered PTU CRM/POS Machines/CAS in effect must reconfigure their system to remove the above-mentioned phrases and comply with the provisions of these Regulations until 31 December 2022. Although such modifications are considered minor enhancements as they do not affect any financial aspect on the system, a written notification to the concerned Revenue District Office (RDO) shall no longer be required because the modifications are mandated by the Regulations.

With these issuances in place, the BIR created a paradigm to further ensure the ease of doing business and deliver government service efficiently. As a result, the BIR reduces taxpayers’ burden of recurring expenditure brought about by the necessity to reprint the forms upon their expiration. Aside from economic benefit, these issuances also signify triumph for the environment as it may lead to lessen the use of paper, a well-meaning move towards environment-friendly agendas.

In summation, RR 6-2022 and RMC 123-2022 confirm that the government recognizes the vital role of taxpayers as its stakeholders, and they heeded public clamor as they continuously improve and streamline government servicing. Truly, in enforcing tax laws and regulations, the equilibrium between the interest of state and the taxpayer should be preserved.



Renier Aries A. Razon is a Supervisor from the Tax Group of KPMG in the Philippines (R.G. Manabat & Co. or RGM&Co.), the Philippine member firm of KPMG International. The firm has been recognized in 2021 as a Tier 1 in Transfer Pricing Practice and in General Corporate Tax Practice by the International Tax Review.

This article is for general information purposes only and should not be considered as professional advice to a specific issue or entity. The views and opinions expressed herein are those of the author and do not necessarily represent KPMG International or KPMG RGM&Co.

For questions and inquiries, feel free to send a message through social media or [email protected]

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