Clarifications on the Provisions of Revenue Regulations No. 6-2022 Relative to the Removal of the Five (5)-Year Validity Period on Receipts/Invoices

August 30, 2022 REVENUE MEMORANDUM CIRCULAR NO. 123-2022 SUBJECT : Clarifications on the Provisions of Revenue Regulations No. 6-2022 Relative to the Removal of the Five (5)-Year Validity Period on Receipts/Invoices TO : All Internal Revenue Officers and Others Concerned This Circular is hereby issued to address and provide uniform answers to the numerous issues and concerns of both internal and external stakeholders relative to the recently issued Revenue Regulations (RR) No. 6-2022 regarding the removal of the five (5)-year validity period on receipts/invoices. Q1. When is the effectivity of RR No. 6-2022? A1. The effectivity date shall be on July 16, 2022, which is fifteen (15) days from the date of its publication which was July 1, 2022. Q2. Who are covered by the aforesaid Regulations? A2. All taxpayers who are/will be using Principal and Supplementary Receipts/Invoices shall be covered by the aforesaid Regulations or taxpayers with/who will apply for any of the following: a. Authority to Print (ATP); b. Registration of Computerized Accounting System (CAS)/Computerized Books of Accounts (CBA) and/or its Components; and c. Permit to Use (PTU) Cash Register Machines (CRM)/Point-of-Sale (POS) Machines and Other Sales Receipting Software. Q3. Can we use the expired but unused receipts/invoices with a validity date of on or before July 15, 2022 after the effectivity of the said Regulations? A3. No. All receipts/invoices which have expired on or before 15 July 2022 are no longer valid for use. In this regard, the Validity Period of receipts/invoices shall be based on the date of issuance of the ATP, as provided below: Date of ATP Unused Receipts/Invoices as of Expiry Date Date of Issue "Valid Until" as reflected in ATP/Receipts/Invoices Can they still be issued? (Yes/No) On or before July 16, 2017 On or before July 15, 2022 No July 17, 2017 onwards July 16, 2022 onwards Yes Please see sample scenarios below: (1) If the date of ATP is on July 13, 2017 with "Valid Until" July 12, 2022, as reflected in the receipts/invoices, the taxpayer can no longer issue the unused invoices/receipts effective July 13, 2022. They have ten (10) days to surrender to the Revenue District Office (RDO) where the Head Office or Branch is registered the unused receipts/invoices for destruction since they are no longer valid. (2) If the date of ATP is on July 13, 2010 with "Valid Until" July 12, 2015, as reflected in the receipts/invoices, and the taxpayer did not surrender the unused receipts/invoices, the taxpayer cannot issue them since they are no longer valid. (3) If the date of ATP is on July 18, 2017 with "Valid Until" July 17, 2022, as reflected in the receipts/invoices, the taxpayer may still issue the unused receipts/invoices by July 17, 2022 until they are fully exhausted. Q4. What should the taxpayer do with the unused/expired receipts/invoices dated on or before July 15, 2022? A4. Pursuant to the provisions of RMO No. 12-2013, all unused and expired receipts/invoices shall be surrendered together with an inventory listing to the RDO where the Head Office or Branch is registered on or before the 10th day after the validity period of the expired receipts/invoices for the destruction of such receipts/invoices. Q5. Can the taxpayer still use the receipts/invoices with existing ATP expiring on or after July 16, 2022? A5. Yes. Taxpayers with receipts/invoices with existing ATP expiring on or after July 16, 2022 may still issue such receipts/invoices until fully exhausted. The phrase, "THIS INVOICE/RECEIPT SHALL BE VALID FOR FIVE (5) YEARS FROM THE DATE OF THE ATP" and the "Validity Period" reflected at the footer of the printed receipts/invoices shall be disregarded . Q6. Is there a penalty if the taxpayer with ATP expiring on or before July 15, 2022 failed to apply for subsequent ATP not later than the sixty (60)-day mandatory period prior to expiration? A6. Taxpayers shall not be liable to pay penalty for late application of ATP. Q7. What are the consequences if taxpayer used/will use the receipts/invoices that expired prior to July 15, 2022? A7. Taxpayer who used unregistered receipts or invoices shall be subject to penalty amounting to P20,000 for the first offense and P50,000 for the second offense. Q8. How does RR No. 6-2022 affect the accreditation of CRM/POS and other Sales Receipting Software? A8. All applications for accreditation of CRM/POS and other Sales Receipting Software shall no longer require the phrases "THIS INVOICE/RECEIPT SHALL BE VALID FOR FIVE (5) YEARS FROM THE DATE OF THE PERMIT TO USE" and the "Valid Until (mm/dd/yyyy)" of PTU to be reflected on the footer of generated receipts/invoices during the evaluation. Q9. How does RR No. 6-2022 affect the registration of CAS and/or its Components? A9. The phrase, "THIS INVOICE/RECEIPT SHALL BE VALID FOR FIVE (5) YEARS FROM THE DATE OF THE ACKNOWLEDGMENT CERTIFICATE" as previously required in RMO No. 9-2021 shall no longer be required to be reflected on the generated receipts/invoices. Q10. How should the taxpayer-user with registered PTU CRM/POS Machines/CAS comply with the provisions of RR No. 6-2022? A10. Taxpayer-users shall be required to reconfigure their CRM/POS Machines/CAS to remove the phrases "THIS INVOICE/RECEIPT SHALL BE VALID FOR FIVE (5) YEARS FROM THE DATE OF THE PERMIT TO USE"/"THIS INVOICE/RECEIPT SHALL BE VALID FOR FIVE (5) YEARS FROM THE DATE OF THE ACKNOWLEDGMENT CERTIFICATE" and "Valid Until (mm/dd/yyyy)." However, it should be noted that a written notification shall no longer be required to be submitted to the concerned RDO although such modifications are considered as minor enhancements due to the fact that such modifications were mandated upon the effectivity of RR No. 6-2022. Q11. Is there a period required within which the taxpayer-user shall remove the phrase and validity period by reconfiguration of the CRM/POS and/or CAS and other machines generating receipts/invoices? A11. Yes. The CRM/POS and/or CAS and other machines generating receipts/invoices shall have to be reconfigured until December 31, 2022 to comply with the provisions under RR No. 6-2022. All revenue officials and employees are enjoined to give this Circular as wide a publicity as possible. (SGD.) LILIA CATRIS GUILLERMO Commissioner of Internal Revenue