Exemption from the Issuance of Sales Invoices of the Copra Dealers of Quezon Province

June 25, 1959 BIR RULING NO. 304-59 Quezon Province Chinese General Chamber of Commerce Lucena, Quezon Gentlemen : Reference is made to your letter dated June 23, 1959 requesting the exemption from the issuance of sales invoices of the copra dealers of Quezon Province. You stated as reasons for the request the following: lexlib "As is the practice and usage long established in the copra business, copra dealers provide themselves with purchase invoices to evidence their purchases but keep no sales invoice. For their sales, they avail of the purchase invoices issued by their buyers, who are mostly reputable exporters and manufacturers, as evidence of this particular transaction. This practice is dictated by peculiarities inherent in the copra business. In every sale, each copra dealer has no immediate control over the total proceeds. Altho the selling price might have been fixed beforehand, yet their product is subject to the classification by their buyer. The buyer's classification of the copra offered for sale is absolute and only after the classification, can the total proceeds of the sale be determined. From this peculiar circumstance you can visualize the impracticability of issuing sales invoices which after all will be superseded by the buyer's purchase invoices." In reply thereto, I have the honor to inform you as follows: As a general rule, sales invoices or receipts are required by the regulations to be issued for every sale made or service rendered. However, the regulations authorizes the Commissioner of Internal Revenue to exempt any person from the issuance of sales invoices or receipts in meritorious cases. As a matter of fact, section 14 of the Bookkeeping Regulations provides that "In case an invoice or a receipt is not issued, the taxpayer concerned shall require the vendor to sign a purchase or expense voucher showing the date, the quantity and description of the articles purchased or the services rendered, the consideration paid therefor, and the name and address of the vendor or lessor together with the number, date and place of issue of his residence certificate". Considering the peculiarities stated by you of the business of the copra dealers of Quezon province, your request that they be exempted from the issuance of sales invoices is hereby granted provided that every sale made by them is covered by purchase vouchers accomplished by the buyers containing the information required by the regulations which should be kept by them as part of their records. LLphil Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue