BIR Ruling

December 21, 1977 Receipts and Invoices in Branch Offices This refers to your letter dated December 19, 1977 requesting authority for your Head Office at Novaliches, Quezon City to continue supplying your seven branches located all over the Philippines invoices and receipts and other accountable forms. It is represented that these invoices and receipts are printed in Metro Manila; that said invoices and receipts are registered with local revenue office where your head office is located; and that the same receipts or invoices are again registered in the revenue offices where the branches are located. In reply, I have the honor to inform you that Presidential Decree No. 1255, the Decree which regulates the printing of receipts or sales commercial invoices only requires that the printing of receipts or sales or commercial invoices be reported or regulated by the Bureau of Internal Revenues. Nowhere is the requirement that said invoices or receipts be printed in the particular plane where they are intended to be used. Under the same decree, however, it is now the obligation of all persons who print receipts or sales or commercial invoices, for every job order, to secure from the Bureau of Internal Revenue an authority to print said receipts of invoices before printing the same. And no authority to print receipts or sales or commercial invoices shall be granted unless the receipts or sales or commercial invoices to be printed are serially numbered and shall show, among other things, the name, business style, taxpayer account number and business address of the person or entity to use the same. This being the case, this Office believes that the head office, which maintains branches in other revenue regions or districts where sales in both main office and branches are required to be issued invoices or receipts, may continue supplying for use of said branch offices receipts or invoices printed in the local of your head office; provided that the abovementioned requirements of P.D. 1255 have been complied with as regards the printing of said receipts or invoices by your head office; that these receipts or invoices are again registered with the local revenue office of the place where your branch office is located; and that the complete address of such branch is, likewise, printed or superimposed in the invoices or receipts. It appears that you were a U.S. serviceman, having completed your tour of duty in the Philippines, with an approved separation order effective October 28, 1976; that the above-described items were purchased by you at Clark AirBase, NavConStapphil San Miguel, or brought with you from the United States upon initial assignment to the Philippines on March 27, 1972; and that being married to a Filipina, you desire to remain in the Philippines to reside and attend school. In reply, I have the honor to inform you that under the foregoing circumstances, you are exempt from the payment of compensating tax provided that said articles will remain in your possession for your actual use. Should you, however, transfer any of the said items to a party who is non-exempt, the latter is considered an importer, subject to the sales or compensating tax, depending upon whether he effects the purchase for the purpose of resale or for his personal use, pursuant to Section 183(b) and 190 of the Tax Code. (SGD.) EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3