Request for Exemption from Issuing Separate VAT and Non-VAT Official Receipts for VAT and non-VAT Taxable Transactions, Respectively

February 14, 1995 BIR RULING NO. 032-95 108-00 000-00 032-95 Pangasiwaan Ng Daungan Ng Pilipinas Marsman Building, South Harbor Port Area, Manila Attention: Mr . Eduardo C . Tolentino Asst. General Manager Finance, Legal, Administration & Management Services Gentlemen : This refers to your letter dated August 4, 1994 requesting exemption from issuing separate VAT and Non-VAT official receipts for your VAT and non-VAT taxable transactions, respectively, for the following reasons: "1. Our non-VATable receipts are tariff in nature and its being non-VATable is therefore easily verifiable; "2. A separate amount column for Value Added Tax can be provided in our Official Receipt to indicate clearly the amount of VAT corresponding to the VATable revenue on a per item basis. VATable revenue/s and non-VATable revenue/s will be segregated and sub-totaled for further clarity; "3. Issuing separate ORs have been creating tremendous problems to us because of the voluminous passengers and cargoes passing thru our ports everyday. The longer time consumed per payee creates adverse public attitude towards the VAT System and the government in general. "One Collecting Officer in our big ports, issues an average of 200 consolidated official receipts on an 8-hour shift which will therefore double to 400 VAT and non-VAT receipts per Collecting Officer per shift. "4. Two separate ORs entails double printing cost for the government. Likewise, common cases are the amount of the VATable receipt is smaller than the printing cost per receipt which add to losses for the government; and "5. Tampering of Official Receipts will be minimized if not eliminated since a copy of all receipts (VATable and non-VATable revenue) will be forwarded to Head Office (for the BIR) serving as a deterrent to tamper. This system will check graft and corruption which is a concern of all government agencies." In reply, please be informed that your request cannot be granted for lack of legal basis. If a taxable person is also engaged in exempt operations, he should issue separate invoices or receipts for the taxable and exempt operations. A "VAT invoice" shall be issued only for sales of goods or services subject to VAT imposed in Sections 100 and 102 of the Tax Code, as amended. (Sec. 108, Tax Code, as amended, as implemented by Sec. 21, Revenue Regulations No. 5-87 and Sec. 29, Revenue Regulations No. 10-94) aisadc Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue