Title
Mandatory Submission of Sales Machines Inventory
Law
Bir Revenue Memorandum Circular No. 36-2015
Decision Date
Jun 8, 2015
The Bureau of Internal Revenue mandates all taxpayers to submit a one-time inventory list of all cash register, point of sale, and special purpose machines generating sales invoices by July 31, 2015, to enhance monitoring and compliance, with penalties for non-compliance including permit revocation and fines.
A

Legal Basis and Reference Circulars

  • Based on Section 6 of the National Internal Revenue Code (NIRC) of 1997, as amended.
  • Implementing Revenue Memorandum Circular No. 36-2015 in line with Revenue Memorandum Circular No. 30-2015 regarding permits to use such machines.

Procedures for Submission

  • Submission must be done in both hard copies and soft copies.
  • Soft copies to be submitted in an Excel format per prescribed schedule (Annex aAa).
  • Soft copy stored on a DVD-Recordable (DVD-R) labeled according to Annex aBa.
  • A notarized Sworn Declaration certifying the truthfulness of submitted data must be attached (format in Annex aCa).

Authentication and Authorized Signatories

  • For corporations, documents must be signed by a principal officer designated through a Board Resolution and sworn to by said officer and the Corporate Treasurer or Assistant Treasurer.
  • Individual taxpayers must personally sign all documents.
  • If representation is by an attorney-in-fact, a notarized Special Power of Attorney (SPA) must accompany the submission.

Submission Deadlines and Offices

  • Deadline for submission is July 31, 2015.
  • Submission to:
    • Large Taxpayers Assistance Division (LTAD), Excise Large Taxpayers Regulatory Division (ELTRD), and Large Taxpayers Division (LTD-Makati/Cebu) for large taxpayers under Large Taxpayers Service (LTS).
    • Respective Revenue District Office (RDO) or Revenue Region (RR) for non-large taxpayers.

Verification Process

  • Relevant BIR divisions and offices responsible to immediately verify and approve pending applications for cancellation or withdrawal of machine use (due to sale or retirement).
  • Ensures updating and validation of machine inventory data.

Consequences of Non-Compliance

  • Automatic revocation of permit to use CRMs/POS/SPMs or similar machines.
  • Immediate post-evaluation of the machines.
  • Imposition of penalties under Section 250 of NIRC, including:
    • PHP 1,000 penalty per failure to file the required list or information return on time.
    • Penalties may increase under Revenue Memorandum Order (RMO) No. 7-2015 if failure is willful (linked to fraud).
  • Inclusion of taxpayer in the priority audit program of concerned Revenue Offices.
  • Payment of penalty does not exempt the taxpayer from submission obligation.

Enforcement and Publicity

  • BIR tasked with enforcing full compliance with the Circular's provisions.
  • All revenue officials and employees instructed to widely disseminate the Circular.
  • The Circular underscores the seriousness of compliance and outlines strict administrative measures to ensure adherence.

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