Summary
RMC No. 77-2024 clarifies the invoicing requirements of RR No. 7-2024, as amended by RR No. 11-2024.
Key points
- Who issues what. A VAT-registered person issues a registered VAT Invoice for every sale, barter, exchange or lease, whatever the amount. A Non-VAT-registered person issues a registered Non-VAT Invoice for transactions of ₱500.00 or more, and for any amount if the buyer asks. The ₱500.00 amount is adjusted every three (3) years from January 22, 2024 using the Consumer Price Index of the PSA.
- ATP and unused Official Receipts. Sellers apply for a new Authority to Print before an Accredited Printer prints invoices. Official Receipts are now supplementary documents. Taxpayers may keep using unused ones as supplementary documents if each page is stamped THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX, or convert them to Invoice or Billing Invoice by striking out the old name and stamping the new one with all required information, including quantity, unit cost and description.
- Invoice types and rules. Any descriptive name may be used if the word Invoice is prominently printed, such as Sales, Cash, Charge, Credit, Service, Billing, Commercial or Miscellaneous Invoice. From April 27, 2024, sellers issue these invoices, and service providers issue a Billing Invoice upon billing. An invoice cannot be issued upon receipt of payment, but an Official Receipt, Payment Receipt or Acknowledgement Receipt may be. Each invoice type has its own serial number set.
- Reports and deadlines. An Inventory Report (Annex C) of unused converted Official Receipts is due until July 31, 2024. A Notice on renaming (Annex D) for CRM/POS/CAS/CBA users is due within thirty (30) days from completion of reconfiguration or on December 31, 2024, whichever comes first. System adjustments are due by December 31, 2024, with extensions of up to six (6) months from that date approved by the Regional Director or the Assistant Commissioner of the LTS.
- Mixed VAT transactions. A VAT-registered person with mixed transactions may issue a single invoice that breaks down Vatable, VAT-Exempt and Zero-Rated sales, or separate invoices each marked VAT-Exempt Sale or Zero-Rated Sale.
- Penalties and input tax. Issuing an Official Receipt or other supplementary document in place of an invoice counts as failure to issue an invoice, with a penalty of not less than ₱1,000.00 but not more than ₱50,000.00 and imprisonment of two (2) to four (4) years under Section 264(a). A non-VAT seller who issues a VAT Invoice owes VAT under Section 106 or 108 without input tax credit, plus a 50% surcharge under Section 248(B). A VAT invoice missing required information makes the seller liable, but the buyer keeps the input tax credit unless the missing item is the amount of sales, VAT amount, registered name and TIN of both parties, description, or date of transaction.
Who is affected
- VAT-registered sellers
- Non-VAT-registered sellers
- Users of CRM, POS, e-receipting or e-invoicing systems
- VAT-registered buyers claiming input tax
Deadlines and effectivity
- Invoicing provisions effective April 27, 2024
- Inventory Report until July 31, 2024
- System adjustments by December 31, 2024, extendable by up to six (6) months
Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.
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