Issuance of Sales or Commercial Invoices or Receipts

April 17, 1959 BIR RULING NO. 207-59 Mr. Alberto Quijano Office of the Chief Accountant Bureau of Public Schools, Manila S i r : In reply to your letter dated January 28, 1959, I have the honor to inform you as follows: 1. Section 204 of the Tax Code, as amended by section 18 of Republic Act 1612 expressly requires all persons subject to internal revenue taxes to issue to the purchaser, customer or client, sales or commercial invoices or receipts, serially numbered in duplicate for each sale or transfer of merchandise or service rendered valued at P2.00 or more and when the gross sales, earnings or receipts of the taxpayer during the preceding year exceed P20,000, a receipt or invoice must always be issued, regardless of the value of the article sold or service rendered. 2. The collection of the 3% percentage tax on gross receipts as required by section 191 of the Tax Code will be adversely affected if we are to consider sufficient the signature of the operators or keepers of hotels or lodging houses on government reimbursement receipts for the amount actually paid by a government official or employee without the necessity of their issuing the corresponding sales invoice or receipt because the operator or keeper of the hotel or lodging house may not return the amount covered by the reimbursement slips for the 3% tax and this Office will not be in a position to discover the same. 3. The documentary stamp tax on hotel receipts is the direct liability of the hotel keeper. The hotel keeper may, however, shift the burden of the tax to the customer. aisadc The documentary stamp is affixed to the duplicate of the receipt issued. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue