Denial of Request for Exception from Procedure Under RMO 83-99 on Authority to Print Invoices and Receipts

November 26, 2001 BIR RULING NO. 053-01 Sec. 236 TC 000-00 Prudential Life Plan Inc . Prudential Life Plan Building 118 Gamboa St., Legaspi Village Makati City Attention: Mr . Ceferino A . Patio, Jr . FVP-Legal/HR Gentlemen : This refers to your letter dated June 28, 2001 requesting exception from the procedures prescribed under Revenue Memorandum Order No. 83-99 which requires that all applications for issuance of Authority to Print Invoices and Receipts shall be filed with the RDO having jurisdiction over the business establishment which will be using the invoices or receipts. Your request is based on the following justification, viz. : "Presently, Prudential Life Plan Group of Companies consisting of Prudential Life Plan, Inc., Prudential Pension Plan, Inc. and Prudential Education Plan, Inc. is in the process of being consolidated into one (1) company which will be later called Prudentialife Plans, Inc. We expect that the consolidation will be approved by the Securities and Exchange Commission sometime during the first week of July 2001. "As a result of the consolidation we are undertaking a Branch Rationalization Program, whereby the company will review and rationalize the operations of its over 100 branch/area offices all over the country. Because of the rationalization of our branch operations it would be extremely difficult to comply with Revenue Memorandum Or der No. 8 3-99." In reply, please be informed that Section 238 of the 1997 Tax Code. as implemented by Revenue Memorandum Order No. 83-99, provides that Authority to Print (ATP) Invoices and Receipts shall be filed with the Revenue District Office having jurisdiction over the business establishment which will be using the invoices or receipts. Since the above provisions does not provide for any exception, this Office regrets to deny your request. Accordingly, invoices and receipts must be printed and registered in the Revenue District Office where the head office of Prudentialife Plans, Inc. is located while invoices and receipts to be used by your branches shall be approved by the respective Revenue district Offices where your branches are located. Very truly yours, (SGD.) RENE G. BAEZ Commissioner of Internal Revenue