Submission of a List of Purchases

October 16, 1990 BIR RULING NO. 201-90 108 000-00 201-90 Gentlemen : This refers to your letter dated August 7, 1990 requesting a ruling as to whether there is a need for your client, a seller of high grade steel to last consumers/end-users, to submit a summary list of sale and purchases as required under Revenue Regulations No. 6-89 as amplified by Revenue Memorandum Circular No. 2-90. aisadc It is represented that your client is engaged in the sale of high grade steel which are used, among others, in the fabrication of coining dyes used by the Central Bank in making coins and for making shaft used in personal motor vehicles, electric motors and appliances; and that it also sells welding electrodes used for stainless water tanks. In reply, Section 23 (c) of Revenue Regulations No. 5-87, as amended by Revenue Regulations No. 6-89, and pertinent portion of Revenue Memorandum Circular No. 2-90, which amplified said provision, are quoted hereunder as follows: "(c) Summary lists . Except as herein otherwise provided, every person liable for the value-added tax, whose gross aggregate sales and receipts exceed P2,500,000.00 a quarter, shall attach to his return a summary of his sales and purchases in separate lists. However, operators of supermarkets, department stores and other sellers of goods and services to last consumers may submit only the list of purchases of goods and services. The list must show the name, address and VAT number of each of his buyer and supplier and the amount of his sales and purchases by totals per buyer or supplier." (Sec. 23 (c), RR-5-87 as amended by RR 6-89) "4.Q. Under the covering Regulations, supermarkets, department stores and other sellers of goods and services to last consumers may submit list of purchases of goods and services. If a taxpayer is a wholesaler and retailer at the same time, is he exempt from submitting the summary list of sale to last consumers? "Ans. Yes, he is exempt from the requirement to submit the list of sales to "last consumers". He is, however, still required to submit the list of his purchases for his wholesale and retail business as well as the summary list of his sales in wholesale business. In this connection, "last consumers" shall refer to persons who purchase goods or services not for resale or for conversion into finished product or to be supplied with services or to be used in connection with VAT-taxable business, but for consumption not in connection with trade or business." (RMC 2-90) Based on the foregoing, your client who sells high grade steel to last consumers/end-users is required to submit a list of purchases but need not submit a list of sales. The summary list of purchases is a 4-column form to be attached to the quarterly VAT return of your client to be filed within 20 days of the month following each taxable quarter showing the name of the supplier, address of supplier, VAT number and total purchases. cd Very truly yours, (SGD.) JOSE U. ONG Commissioner