Title
Maintece, Retention, and Submission of Electronic Records
Law
Bir Revenue Regulations No. 9-2009
Decision Date
Dec 23, 2009
BIR Revenue Regulations No. 9-2009 mandates large taxpayers to maintain computerized accounting systems and electronic records for tax compliance, ensuring accessibility and integrity of data for Bureau of Internal Revenue audits.
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Key Definitions

  • Database Management System: software that manages data accessibility.
  • Electronic Data Interchange (EDI): structured computer-to-computer business transactions.
  • Electronic Record: electronic format information, excluding paper-based or storage-only imaging.
  • Electronically Readable Form: non-proprietary, compatible, useable electronic copy.
  • Storage-only Imaging System: hardware/software for storing paper source documents without data manipulation.
  • Taxpayer: entities required to keep books for tax liability determination.
  • Electronic Record Keeping: electronic systems to create, process, store financial records.
  • Media: physical form of stored information (paper, disks, tapes).
  • CD-R/DVD-R: write-once optical storage media.

General Electronic Recordkeeping Requirements

  • Taxpayers must maintain all records for accurate tax liability determination.
  • Records held in both electronic and hard-copy must be made available electronically upon request.
  • Compliance demonstration via hard-copy documents is allowed but does not exempt electronic record obligations.

Requirements for Large Taxpayers

  • Large Taxpayers must maintain CAS with books in electronic format.
  • Manual book maintainers must register CAS by December 31, 2009.
  • Software deficiencies do not exempt recordkeeping responsibilities.

Electronic Records Specific Requirements

  • Records must contain detailed transaction-level information for tax verification.
  • Records must be retrievable and convertible to standard format per RR No. 16-2006.
  • Records are to be created only in the ordinary course of business; no construction of records otherwise required.

EDI Requirements

  • Records from EDI must equal detail level of paper records.
  • Codes used for data elements must be convertible to auditable formats.
  • Original EDI documents need not be retained if an audit trail and required information are preserved.

Electronic Data Processing System Requirements

  • Electronic accounting systems must provide detailed audit trails linking source documents to financial accounts.
  • Taxpayers must retain source documents supporting electronic records.

Business Process Information

  • Taxpayers must provide descriptions of business processes generating records upon BIR request.
  • Must demonstrate system controls, data flow, and anti-tampering measures.
  • Documentation includes record layouts, field definitions, file descriptions, and account charts.
  • Certain mandatory fields required for key accounting journals and books.

Transaction Integrity and Security Controls

  • Access control limiting user permissions.
  • Input/output controls ensuring accuracy and security.
  • Processing controls maintaining information integrity.
  • Backup controls for recovery and preservation.
  • Modification of records allowed only via documented journal entries with full details.

Changes to Business Systems

  • Access to historical data must be preserved during system changes.
  • Detailed documentation of changes required and must be reported before implementation.
  • New systems must maintain adequate detail, audit trails, internal controls, data export capability, backup procedures, and BIR access.

Electronic Records Maintenance and Storage Location

  • Extraction and conversion capabilities per RR No. 16-2006 are required.
  • Backup media must follow manufacturer guidelines, stored safely away from hazards.
  • Taxpayers must ensure proper archiving and backup effectiveness.
  • Backup procedures require labeling, logging, software/version info, periodic testing.
  • Records must be stored primarily in the Philippines or designated places; foreign-held records can comply if copies accessible locally.
  • Backup copies to be stored locally for disaster recovery.
  • Internet-hosted businesses must maintain records within the Philippines.
  • Third-party custodians require prior BIR notification; taxpayer remains liable.

Access and Submission of Electronic Records

  • Access to records can be through provision of equipment and personnel by taxpayer or third-parties.
  • Records may be submitted in standard record format on agreed media with original files.
  • Alternative methods may be agreed upon.

Alternative Storage Media

  • Conversion of hardcopies to microfilm, microfiche, or storage-only imaging is allowed with conditions.
  • Documentation of conversion procedures and quality assurance required.
  • Secure storage, clear labeling, and authorized destruction protocols must be observed.
  • Legibility and readability standards mandated.
  • BIR may require facilities for document reproduction.
  • Prior BIR approval needed before use.

Effect on Hard-Copy Records

  • Requirement to retain paper originals remains, unless no hard-copy produced in ordinary business.
  • Credit/debit card transaction printouts must be kept unless equivalent details are electronically retained.
  • Temporary computer printouts need not be retained.
  • BIR may request hard-copy substitutes during audits.

Retention Period

  • Records to be retained pursuant to Section 235 of NIRC unless BIR states otherwise.

Registration

  • All computerized books, electronic systems must be registered per RMO No. 29-2002 and related issuances.

Penalties

  • Violations subject taxpayer to prosecution per Section 255 NIRC penalties plus others applicable.

Repealing Provisions

  • Inconsistent prior regulations revoked or amended.
  • Partial invalidity of provisions does not affect others.

Effectivity

  • Regulations effective 15 days post-publication in a general circulation newspaper.

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