BIR Ruling

October 18, 1976 The Revenue District Officer Revenue District No. 50 Masbate, Masbate S i r : This refers to your letter dated May 31, 1976 requesting a ruling as regards the requirements of issuing sales invoice based on the following representations: "a) Merchants engaged in the business of buying and selling copra. When these merchants purchased copra from copra producers, they issue purchase invoices wherein are stated the name of the seller, address, date and the amount of purchase. But when they sell the copra to other outlets, they do not issue sales invoices. They claim that they are exempt from issuing sales invoices because their outlets any way will issue the corresponding purchase invoices. b) Coconut plantation owners producing copra. These owners harvest coconuts from their plantation and convert the coconuts into copra, then sell the same to copra dealers. This transaction is not covered by sales invoices but instead covered by purchase invoices issued by the buyers who are copra dealers." In reply, you are informed that under Section 204 of the Tax Code, "all persons subject to an internal revenue tax shall, for each sale or transfer of merchandise or for services rendered value at two pesos or more, prepare and issue sales or commercial invoices or receipts serially numbered in duplicate showing, among other things, their names, or styles, if any, and business address: . . ." Since the merchants and coconut plantation owners are subject to internal revenue tax, they are required to issue sales invoices for each sale effected by them pursuant to the abovequoted provision of the Tax Code. cdt Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3