Title
Strict Penalties for Non-Submission of VAT Sales Lists
Law
Bir Revenue Memorandum Order No. 12-2009
Decision Date
Apr 28, 2009
BIR Revenue Memorandum Order No. 12-2009 mandates strict enforcement of penalties for non-submission of quarterly Summary Lists of Sales and Purchases, aiming to enhance taxpayer compliance and curb tax evasion.

Law Summary

Low Compliance and Impact on Tax Administration

  • Less than 30% of required taxpayers comply with the submission requirement.
  • Many taxpayers prefer paying a minimal penalty rather than submit data.
  • Non-compliance impedes the Bureau’s ability to verify taxable transactions, leading to significant revenue losses.
  • Such practices indicate indirect tax evasion or tax avoidance by businesses.

Enforcement Objectives

  • Strengthen enforcement against non-compliant taxpayers.
  • Strictly implement penalties for failure to submit the required summaries.
  • Increase voluntary compliance and thereby enhance revenue collections.

Enforcement Policies for Non-Submission

  • Failure to submit required Summary Lists or submission of erroneous, incomplete, or falsified data justifies issuance of a Subpoena Duces Tecum compelling immediate submission.
  • Upon submission after subpoena, a compromise penalty of Ten Thousand Pesos (P10,000) per non-submission applies.

Consequences of Continued Non-Compliance

  • Persistent refusal to submit after subpoena equates to failure to supply accurate information under Section 255 of the National Internal Revenue Code.
  • Triggers administrative and criminal proceedings, including:
    • Fine of not less than Ten Thousand Pesos (P10,000).
    • Imprisonment from one to ten years.
  • Additional penalties apply for fraudulent acts related to filing or withdrawing returns.

Corporate Liability

  • Corporations failing to submit Summary Lists expose their officers and employees to criminal liability.
  • Section 256 of the Tax Code provides penalties including:
    • Corporate fines ranging from Fifty Thousand Pesos (P50,000) to One Hundred Thousand Pesos (P100,000) per offense.

Repealing Clause

  • Any prior issuances inconsistent with this Order are repealed, modified, or amended accordingly.

Immediate Effectivity

  • The Order takes effect immediately upon issuance by the Commissioner of Internal Revenue on April 28, 2009.

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