Simplified guidelines and procedures on the use of CAS/CBA and its components
(Revenue Memorandum Order No. 09-2021 issued on February 19, 2021)
This Tax Alert is issued to inform all concerned on simplified guidelines and procedures on the use of Computerized Accounting System (CAS), Computerized Books of Accounts (CBA), and/or its components, including Electronic Storage System (ESS), middleware and other similar systems, in relation the provisions of Revenue Memorandum Circular No. 5-2021.
Registration
- The requirement for Permit to Use (PTU) is no longer applicable. All taxpayers who intend to use CAS, CBA, and/or its components, including ESS, middleware and other similar systems (collectively referred herein as “System”) shall submit the documentary requirements (Annex A of the RMO) with the Client Support Section (CSS) of the RDO/LT Office where it is registered manually or via electronic mail (e-mail).
- All documents shall be submitted to the RDO/LT office where the head office is registered except:
- Branch office adopts a “system” ahead of the head office
- Branch office adopts “system” different form the other branches and its head office
- Affiliated companies, sister companies, franchisees, closely held corporations and other similar companies related to a parent company shall submit separately the required documentary requirements where the aforesaid companies are registered.
- The System must strictly comply with the Standard Functional and Technical Requirements (Annex B of the RMO).
- The concerned RDO/LT Office shall issue an Acknowledgment Certificate (AC) within three (3) working days from receipt of complete documentary requirements. In case there are discrepancies in the information provided on the submitted documentary requirements, a Notice/Letter of Denial shall be issued.
- No system demonstration nor pre-evaluation shall be conducted as a condition for the registration of the System.
- Taxpayers who will avail the services of Tax Service Providers (TSPs) or third-party software provider for the use of a system/software must register such system with the BIR prior to the effectivity of their contract with the TSPs or third-party software provider.
- The registration of the CRMs/POS Machines and Other Sales Receipting System/Software shall be different from the registration of the System, unless the same is connected through a network or linked to CAS/CBA.
- In case of a major system enhancement, taxpayers must submit an update of registration. In case of minor system enhancement, the taxpayer must submit a written notification to the RDO/LT Office stating the minor specific enhancements of the system.
Use of Receipts/Invoices
- Taxpayers with duly registered System, without system-generated principal and/or supplementary receipts/invoices, should apply for Authority to Print (ATP) receipts/invoices based on existing revenue issuances.
- System-generated principal and/or supplementary receipts/invoices must comply with the mandatory information required to be indicated in the receipts/invoices, except for the following which are applicable only for CRM/POS Machine:
- Machine Identification Number (MIN);
- Serial Number of the CRM/POS Machine; and
- Accreditation Details of the CRM/POS Supplier.
- In case of systems downtime, taxpayers with duly registered System with no redundancy or automatic switchover, who are using it for receipting and invoicing, shall be allowed to issue manual receipts/invoices. Approved ATP reserved or set aside for use during systems downtime should not exceed one thousand (1,000) sets at a time.
Transitory Provisions
- All applications filed after February 23, 2020 shall be processed following the above guidelines and procedures.
- All taxpayers with pending applications for Permit to Use CAS, CBA, and/or its Components, which were filed with the National Accreditation Board (NAB) and are pending with NAB as of February 23, 2020 shall be processed under RMC No. 10-2020 .
- Approved PTUs of taxpayers shall remain valid unless the issued PTU has been revoked/expired or the system has been enhanced and no registration update was made.