THE Bureau of Internal Revenue (BIR) recently issued Revenue Memorandum Circular (RMC) 69-2020, updating the procedures in accordance with the requirements of Republic Act 11032, otherwise known as the “Ease of Doing Business and Efficient Government Service Delivery Act of 2018” in connection with the procedures for cancelling Permit to Use (PTU) Cash Register Machines (CRM), Point-of-Sale (POS) machines, and other similar machines.
1. The cancellation of the PTU CRM/POS machine shall be processed by the Revenue District Office (RDO) or Large Taxpayers (LT) Office having jurisdiction over the taxpayer’s business address where the machine was registered.
2. The taxpayer shall notify the concerned RDO/LT Office in writing on their request to cancel the PTU within five days from the date the machine was last used or withdrawn from use, stating the reason(s) for the cancellation and other information, such as, but not are limited to, the following:
a) Permit number;
b) Machine Identification Number (MIN);
c) Type of machine;
d) Machine serial number, brand, or model;
e) Software name and/or version; and
f) Grand accumulated sales as of the last day of the use of the machine.
3. The taxpayer shall submit the following documents as an attachment to the letter or to the assigned Revenue Officer at the time of machine inspection:
a) Copy of the Z-reading (for POS machines) or audit tape (for CRM) showing the reset counter number and EOD/Z-Counter Reading as of the last day of the use of the machine(s);
b) Copy of the back-end report (for POS machines) or cash register sales book page (for CRM) as of the last day of the use of the machine(s);
c) Original copy of the PTU issued;
d) Original copy of the Decal;
e) Reprint copy of the last invoice/receipt generated as of the last day of the use showing the serial number of such invoice/receipt;
f) Copy of the Z-reading or EOD report or its equivalent showing that the sales machine was reset to zero or initialized;
g) For new or upgraded software (loaded in the same machine where the old software is installed): Copy of the Z-reading/EOD Report or its equivalent showing the initial reading of the newly installed software.
4. Actual inspection of the CRM or POS shall be mandatory, in case of its withdrawal from use or its transfer to another branch of the company. However, in case of modification or upgrade of the software being used, the actual inspection of the machine may be dispensed with so as not to disrupt the normal business operations of the taxpayer under the following conditions:
a) New or upgraded software shall be set up in the same hardware or machines where the old POS software is installed;
b) POS machines have a PTU issued through the Electronic Accreditation and Registration (eAccReg) System;
c) The new or upgraded software will be implemented, deployed, or rolled-out nationwide or in branches or by franchisees located in different RDOs; and
d) The changing or loading of the new or upgraded software in the POS machines will be implemented immediately after business hours.
5. In case of withdrawal from use or transfer of the CRM/POS to another branch of the taxpayer, the assigned Revenue Officer shall inspect the machine.
6. Non-payment of the penalties at the time of the request for cancellation of the PTU shall not be a ground for the non-issuance of the Cancellation Certificate.
7. The assigned Revenue Officer shall submit a Memorandum Report on the results of the inspection upon completion of the machine inspection and submission of the required documents by the taxpayer. Such report shall be approved by the Assistant Commissioner, LTS/RDO.
8. Upon approval of the Memo Report of the assigned Revenue Officer, the Chief, Client Support Section of the RDO or the Chief, LT Office or its authorized staff shall cancel the PTU and the MIN of the machine in the eAccReg system and generate the Cancellation Certificate.
9. In compliance with the processing time in the Citizen’s Charter, the Cancellation Certificate must be issued within seven days from receipt of the letter request of the taxpayer by the concerned RDO/LT Office. If the inspection of the machine was dispensed with, the Cancellation Certificate shall be issued to the taxpayer within three working days from receipt of the complete requirements by the RDO/concerned LT office.
10. The LT office/RDO shall approve of the application for PTU through eAccReg within three days from the receipt of such application, as mandated under the Citizen’s Charter of the BIR.
11. To authorize the simultaneous registration in eAccReg system of the new accredited software or upgraded software to be installed in the same machine with application for cancellation of the old software, the taxpayer shall secure approval in writing from the concerned LT office/RDO to add a distinct prefix/suffix to the serial number of the sales machine to allow the registration of the new software consisting of the serial number of the machine, followed by the prefix/suffix.
Some of the procedures stated are a reiteration of the provisions of RMC 72-2018. To clarify, the policies, requirements, and procedures in RMC 72-2018 apply only to machines found to have requested cancellation of PTU during post-evaluation, but have not been acted upon by the concerned LT office/RDO. Otherwise, the provisions on the cancellation of PTU under RMC 69-2020 shall apply.
Please be guided accordingly.
P&A Grant Thornton
Certified Public Accountants