Non-attachment of the Residence Certificate of the Purchaser, Customer, or Client to the Receipts is Not Subject to Any Penalty

June 20, 1958 BIR RULING NO. 333-58 Mr. Nemesio Garcia P.O. Box No. 3 Bacolod City Gentlemen : In answer to the questions propounded in your letter dated May 27, 1958, I have the honor to inform you as follows: cdt There is no law or regulation requiring the taxpayer who issues a sales receipt or invoice for each sale or transfer of his merchandise or for services rendered by him, valued at P50 or more, to attach to the said receipts or invoices the residence certificate of his customer or client. What is required by the provisions of Section 204 of the Tax Code is that such receipts or invoices shall be serially numbered in duplicate and shall contain at least the name, address, and style, if any, of both the person issuing them and the purchaser, customer, or client. In addition, the aforesaid receipts shall also show the number, date, and place of issue of the residence certificate of the purchaser, customer, or client, pursuant to Section 15 of Revenue Regulations No. V-1. It may be stated, however, that a notation in the invoice to the effect that the number, date, and place of issue of the purchaser's or customer's residence certificate is on file in the taxpayer records is substantial compliance with the aforesaid requirements under the said Regulations. Accordingly, the failure to attach the residence certificate of the purchaser, customer, or client to the aforementioned receipts is not violative of any internal revenue law or regulations and is, therefore, not subject to any penalty. cdtech Very truly yours, (SGD.) JOSE P. TRINIDAD Acting Commissioner of Internal Revenue