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Tax Alert

Amended Transitory Provisions on Invoicing Requirements under EOPT Act

(Revenue Regulations 11-2024, June 13, 2024)

This Tax Alert is issued to inform all concerned on the amended transitory provisions on the invoicing requirements, pursuant to Republic Act No. 11976, also known as Ease of Paying Taxes (EOPT) Act.

A. Manual and Loose-leaf Invoicing

1. Below are the updated options for taxpayers with manual invoicing with regards to unused official receipts:

2. The stamping of Official Receipt as Invoice or Billing Statement/Statement of Account/Statement of Charges as Billing Invoice by taxpayers does not require approval from any Revenue District Offices/LT Offices/LT Divisions but must comply with Section 8(2.3) of RR No. 7-2024. 

3. All unused manual and loose leaf ORs and BSs/SOAs/SOCs to be converted as Invoice and Billing Invoice, respectively shall be reported by submitting an inventory of unused ORs/ BSs/SOAs/SOCs, indicating the number of booklets and corresponding serial numbers, in duplicate original copies, on or before July 31, 2024 to the RDO/LT Office/LT Division where the Head Office or Branch Office is registered. The receiving branch RDO shall transmit the original copy to the Head Office RDO and retain the duplicate copy.

Pursuant to RMC No. 66-2024, taxpayers shall have the option to submit their Inventory Report being required under RR No. 7-2024 electronically:

a) via email through Taxpayer Registration-Related Applications (TRRA) Portal which is accessible in the BIR Website under the eServices section (refer to Annex A for the); or 

b) via direct email of the Inventory Report and Notice to the Compliance Section of the Revenue District Office (RDO).

See RMC No. 66-2024 Annex A.pdf (bir.gov.ph) for the User Guide on the electronic submission of inventory, and RMC No. 66-2024 Annex B.pdf (bir.gov.ph) for the List of Email Address of RDO's Compliance Section.

Taxpayers without email or internet access may still manually submit their Inventory Report and Notice to the Compliance Section of the RDO where the concerned Head Office or Branch is registered.

4. The converted ORs/BSs/SOAs/SOCs shall contain the required information under Sec 6 (B) of RR 7-2024 including quantity, unit cost and description or nature of service. If not originally indicated, such information may also be stamped.

5. The converted ORs/BSs/SOAs/SOCs shall be considered valid for claiming of input tax by the buyer/purchaser and can serve as proof of both sales transaction and payment at the same time for the period issued from April 27, 2024 until they are fully consumed, provided that the converted Invoice/Billing Invoice to be issued bears the stamped "Invoice/Billing Invoice" and there is no missing information as enumerated under Section 3(D)(3) of RR No. 7-2024.

6. Effective April 27, 2024, any manual/loose leaf "Official Receipts" issued without a stamped "Invoice" will be considered supplementary documents as provided in Section 8(2.1) of these Regulations, and ineligible for input tax claims.

7. Taxpayers should obtain newly printed invoices with an Authority to Print (ATP) before fully using or consuming the converted Official Receipts/Billing Statement/Statement of Account/Statement of Charges.

B. Electronic Invoicing

1. Taxpayers using duly registered CAS or CBA with Accounting Records (AR), needs to revisit their system to comply with the EOPT. Since the system enhancement will have a direct effect on the financial aspect, shall require a major system enhancement. The previously issued Acknowledgement Certificate (AC) or Permit to Use (PTU) shall be surrendered to the RDO where the concerned taxpayer is registered, and a new AC shall be issued.

The reconfiguration of machines and systems shall be undertaken on or before December 31, 2024. Any extension due to enhancement of systems shall be approved by the concerned Regional Director or Assistance Commissioner of the LTS which shall not be longer than 6 months from December 31, 2024.

2. Taxpayers using CRM/POS/E-receipting/E-invoicing may change the word “Official Receipt (OR)” to “Invoice,” “Cash Invoice” “Charge Invoice,” etc., whichever may be applicable, without the need to notify the RDOs having jurisdiction over the place of business of such sales machines.

This reconfiguration is considered a minor system enhancement which shall not require reaccreditation of the system nor the reissuance of the PTU.

3. The serial number of the renamed Invoice to be issued by CRM/POS machines, e-receipting or electronic invoicing software shall start by continuing the last series of the previously approved OR. A notice indicating the starting serial number of the converted Invoice shall be submitted to the RDO/LT Office/LT Division where the machines are registered, in duplicate copies, within 30 days from completion of machine/system reconfiguration/enhancement or from December 31, 2024, whichever comes first.

See above discussion on the submission of inventory of converted ORs/BSs/SOAs/SOCs for the electronic submission of the notice.

4. Documents issued by CRM/POS machines, e-receipting or electronic invoicing software containing the word "Official Receipt" from April 27, 2024 until the completion of machine/system reconfiguration/enhancement shall be considered as valid for claiming of input tax by the buyer/purchaser until December 31, 2024 or until the completion of machine/system reconfiguration/enhancement, whichever comes first, subject to the following conditions:

  • There is no missing information as enumerated under Section 3(D)(3) of RR No. 7-2024; and
  • The machine/system printed/generated "Official Receipt/ Billing Statement/Statement of Account/Statement of Charges" is converted by striking through the term "Official Receipt/ Billing Statement/Statement of Account/Statement of Charges" and stamping the word "Invoice/Billing Invoice" on the document.

5. Issuing "Official Receipt" (with or without strikethrough) generated by CRM/POS machines, e-receipting, electronic invoicing software, CAS or CBA with AR for the sale of goods or services after December 31, 2024 or until the completion of machine/system reconfiguration/enhancement, whichever comes first, and issuing manual/loose leaf "Official Receipt" without converting them to "Invoice" for the sale of goods or service starting April 27, 2024, will not be considered as evidence of sales of goods or services and shall be tantamount to failure to issue or non-issuance of Invoice required under Section 6(A) RR No. 07-2024.

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