BIR Revenue Memorandum Circular No. 77-2024 explains how the invoicing rules in Revenue Regulations No. 7-2024, as amended by RR No. 11-2024, apply to VAT-registered and non-VAT sellers and how unused Official Receipts could be handled during the transition. Its central rule is that an invoice documents a sale; an Official Receipt is generally supplementary. The circular was issued July 11, 2024, and the invoicing provisions it discusses took effect April 27, 2024. Its transition deadlines are historical, so check later BIR issuances before relying on them for current compliance.
What RMC No. 77-2024 says
The Bureau of Internal Revenue issued Revenue Memorandum Circular No. 77-2024 on July 11, 2024. Its subject is “Clarification on the Invoicing Requirements Provided Under Revenue Regulations (RR) No. 7-2024, as Amended by RR No. 11-2024.” The issuance was filed with the UP Law Center National Administrative Register on July 16, 2024, under registration number 24-0760; the catalog entry is available from the National Administrative Register.
The circular describes the EOPT Act and RR No. 7-2024 shift to invoices as the primary sales document for goods and services. An Official Receipt is generally supplementary under that regime. The BIR states that the invoicing and transition provisions at issue took effect April 27, 2024.
When sellers must issue an invoice
RMC No. 77-2024 distinguishes sellers by VAT registration. The requirements below reflect the circular’s text and should not be treated as confirmation that the same threshold or procedures remain unchanged today.
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| Seller | Rule described in the circular |
|---|---|
| VAT-registered | Issue a duly registered VAT Invoice for every covered sale, barter, exchange, or lease of goods or property, and every covered sale, barter, or exchange of services, regardless of amount. |
| Non-VAT-registered | Issue a duly registered Non-VAT Invoice for a covered transaction valued at ₱500 or more. Issue one at any amount if the buyer requests it. |
The non-VAT ₱500 threshold
The circular’s digest also says an invoice is required when the end-of-day aggregate of transactions that were individually below ₱500 exceeds the threshold. It says the ₱500 figure is to be adjusted to present value every three years beginning January 22, 2024, using the Consumer Price Index published by the Philippine Statistics Authority. The sources cited here do not establish whether a later adjustment changed the threshold; verify current BIR guidance rather than assuming ₱500 is still the applicable amount.
What to do with unused Official Receipts
The circular describes two options for unused Official Receipts: retain them as supplementary documents or convert them into invoices under its requirements. It says every page kept for supplementary use must bear the phrase “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.”
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Converting receipts into invoices
For conversion, the circular describes striking out the old document label and stamping an appropriate invoice label. The converted document must include the required transaction information, including quantity, unit cost, and a description of the goods or nature of the service. The digest says missing information could be stamped on the document at conversion.
The reporting steps differed by format. For converted manual or loose-leaf receipts, the circular described an inventory report identifying booklets and serial numbers. For converted machine- or system-generated receipts, it described continuing the numbering series from the last Official Receipt number and notifying the relevant BIR office of the starting number and start date.
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Newly printed invoices and Authority to Print
The circular says a seller should obtain a new Authority to Print (ATP) for invoices and secure it before an accredited printer prints them. A taxpayer converting old receipts could use them during the transition subject to the circular’s conditions, while obtaining newly printed invoices with an ATP before the converted receipts were fully consumed.
Invoice labels, payment receipts, and required details
RMC No. 77-2024 allows descriptive invoice titles such as “Invoice,” “Sales Invoice,” “Cash Invoice,” “Charge Invoice,” “Credit Invoice,” “Billing Invoice,” and “Service Invoice,” among others, provided the word “Invoice” is prominently printed.
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For a service provider that bills customers, the circular says to issue a Billing Invoice upon billing with the required transaction information. An Official Receipt or other payment or acknowledgment receipt may be issued when payment is later collected, but it does not replace the invoice documenting the sale.
For input tax credit purposes, the digest lists transaction and party information that includes the sales amount, VAT amount, registered names and TINs of buyer and seller, description of the goods or service, and transaction date. Missing details can affect a buyer’s ability to use the VAT amount as input credit and may expose the seller to noncompliance consequences.
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- 【2 copies】Our invoice book is 5-1/8” x 7-29/32”, you can get 2 copies of high-quality receipt book per package. Unique horizontal invoice sheet, after recording customer information, you can record details of up to 12 items.
- 【50 sets of 2-part carbon-free copy】Receipt book for small businesses is carbon-free copy paper. Each invoice book for small business has 50 sets of invoices, each set has two parts in white/light yellow. Take out the white customer receipt, the yellowish, carbon-free copy remains on your record. And each group of invoices has a tearing auxiliary line at the top, which can help you tear off the invoices faster and better, protecting the integrity of the invoices.
- 【Surrounding rear cover】The back cover on the back of the receipt book is wraparound. When you fill in the invoice, you can open the folded back cover and place it under the set of invoices you want to fill in, so as to prevent the written content from rubbing onto the subsequent copy of the invoice, causing waste of the invoice.
- 【Consecutive Numbering】The enlarged red 6-digit number in the upper right corner of each set of invoices is unique and non-repetitive and is consecutively numbered with the invoice numbers that follow, which helps you quickly browse your order.
- 【Custom Space】Each sales order form has space for your company stamps. You can use invoice book records to fill in sales orders, purchase orders, and advance orders.
Numbering and mixed VAT transactions
The circular describes separate serial-number series for different invoice types; a distinct prefix or suffix may be used. For converted system-generated receipts, the described series continued from the last Official Receipt number, with a notice to the relevant BIR office stating the starting number and start date. For converted manual or loose-leaf receipts, the described report identified the booklets and serial numbers.
A VAT-registered seller with VATable, VAT-exempt, and zero-rated sales could use one invoice or separate invoices, according to the circular. With one invoice, the relevant sales and VAT amounts should be broken down. With separate invoices, the appropriate “VAT-Exempt Sale” or “Zero-Rated Sale” label should be prominent.
Transition dates in the circular—and their status
The dates below are historical deadlines stated in the 2024 circular, not open filing windows or confirmation of current requirements.
| Item | Date or timing stated in RMC No. 77-2024 |
|---|---|
| Invoicing and transition provisions took effect | April 27, 2024 |
| Inventory report for converted manual or loose-leaf Official Receipts | July 31, 2024 |
| Notice for converted system-generated receipts | Within 30 days after machine or system reconfiguration or enhancement, or by December 31, 2024, whichever came first |
| System adjustments | On or before December 31, 2024; the circular described a possible approved extension of no more than six months from that date |
The BIR digest and circular establish what RMC No. 77-2024 said, but the sources available here do not establish whether later BIR issuances amended or superseded any provision, deadline, or extension. Check current BIR issuances before acting, especially if a receipt conversion or reporting obligation remains unresolved.
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Penalties and case-specific advice
The BIR digest reports that, after the prescribed period, issuing an Official Receipt instead of a required invoice may be treated as failure to issue an invoice. It gives a penalty range of ₱1,000 to ₱50,000 and imprisonment of two to four years under Section 264(a) of the Tax Code. The digest also says a non-VAT seller that issues a VAT Invoice may incur VAT and a 50% surcharge, in addition to percentage-tax liability. These are consequential legal claims drawn from the circular’s 2024 explanation; the applicable law, later issuances, and specific facts should be checked before treating them as advice for a particular transaction.
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