Question & AnswerQ&A (BIR REVENUE MEMORANDUM CIRCULAR NO. 2-90)
Every person liable for VAT (whether registered or not) whose gross sales and/or receipts exceed P2,500,000.00 a quarter is required to submit the Summary List.
The regulations took effect starting January 1, 1990.
The list must include: names, addresses and VAT numbers of suppliers and amounts of purchases (exclusive of VAT); names, addresses and VAT numbers of buyers and amounts of sales (exclusive of VAT); and customs import entry number, amount of importation and VAT paid per entry.
The Summary List must be attached to the quarterly VAT return and submitted within 20 days of the month following each taxable quarter.
The seller must give the 1st and 2nd copies to the buyer and retain the 3rd and 4th copies. Government buyers submit the 2nd copy to the Revenue District Office, and buyers under zero-rating or exemption attach the 2nd copy to their VAT returns. Sellers attach the 3rd copy to their VAT returns supporting zero-rated or exempt sales.
Yes, zero-rated sales are considered taxable and subject to VAT, so the submission of the summary list is required, except exporters need not submit a summary list of export sales.
No, only VAT-taxable sales are counted in determining the minimum qualifying gross sales or receipts.
No, whether a transaction is subject to VAT depends on the nature of the transaction, not the purchaser. Government agencies may claim exemptions only under special laws or international agreements.
Yes, photocopies may be used initially, but the four-copy invoice requirement was strictly enforced starting April 1, 1990.
Yes, the regulations do not exclude purchases from non-VAT persons, so these must be included in the summary lists.
A taxpayer becomes exempt only after the quarterly gross sales or receipts fall below the minimum amount for four consecutive quarters following the last quarter when sales exceeded the minimum.
The format specified in Annex 'Da' of the Revenue Regulations must be followed for submission using magnetic tapes or diskettes.