Application for permit to
Accounting System (CAS) DESCRIPTION | TAX FORM | DOCUMENTARY REQUIREMENTS | PROCEDURES | DEADLINES | RELATED REVENUE ISSUANCES | CODAL REFERENCE | FREQUENTLY ASKED QUESTIONS
Computerized Accounting System (CAS) refers to the integration of different component systems to produce computerized books of accounts and computer-generated accounting records and documents.
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BIR Form 1900 - Application for Authority to Adopt Computerized Accounting System or Components Thereof
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A. Initial Application to Adopt CAS And Or Components Thereof
-Accomplished BIR Form 1900 (Application for Authority to Adopt Computerized Accounting System (CAS) and/or Components Thereof/Loose-leaf Books of Accounts, 2002 Enhanced version) and/or BIR Form 1907 (Application for Permit to Use Cash Register Machine/Point of Sale Machine, 2002 Enhanced Version)
-Photocopy of BIR Certificate of Registration
- Photocopy of Previously Issued Permit, if applicable
- Photocopy of Current Registration Fee Payment
- Location map of the place of business
- Inventory of previously approved unused Invoices and receipts, if applicable
- List of branches that will use CAS, if any
- Application Name and Software Used (Development & Database)
- Functions and Features of the application
- System Flow/s
- Process Flow
- Back-up Procedure, Disaster and Recovery Plan
- Sworn Statement and Proof of System Ownership
- List of Reports and Correspondences that can be generated from the system with their description, purpose and sample layout
- Facsimile of System Generated Loose-leaf Books of Accounts and List thereof/Receipts/Invoices
- Additional requirements in case of affiliated companies/sister companies, franchisees and branches:
- Photocopy of previously issued permit for mother/sister company or another branch using the same system, if applicable
- Certification from the Computerized System Evaluation Team (CSET), which previously evaluated the approve system
B. Application For System Enhancement/Modification
- Photocopy of the previously issued Permit to Adopt CAS or Components Thereof; and
- Letter to the BIR detailing the enhancement/modification to be made on the previously approved CAS or Components Thereof
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A. For Initial Application
All Applications for Permit to Use CAS, whether by the Head Office or branches, shall be filed at the RDO /LTAD I or II/LTDO having jurisdiction over the Head Office (HO) of the taxpayer, except in the following cases:
1. The branch adopts CAS ahead of the HO - the application shall be filed by the Branch with the RDO having jurisdiction over the Branch with a certification that the HO does not use CAS. In the event that the HO later adopts the same CAS and the branch with the previously issued permit shall be linked to it, the permit to be issued to the HO shall include a new permit for the said Branch, which shall supersede the previously issued permit.
2. The Branch adopts a different CAS from that of its HO - it shall apply for permit to adopt CAS at the BIR office having jurisdiction over the Branch.
The Permit for CAS shall be issued after a demonstration of the applied system has been evaluated and recommended for approval by the CSET.
B. For Application for System Enhancement/Modification on the Previously Approved CAS or Components Thereof
Taxpayer submits a letter to the RDO or the concerned office of the LTS that previously issued the permit to adopt CAS about the enhancement and/or modification on the system together with a photocopy of the previously issued Permit to Adopt CAS or Components thereof.
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Application for authority to use CAS must be filed before the system is used.
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RELATED REVENUE ISSUANCES
RMO No. 21-2000 and RMO No. 29-2002
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Section 232 to 235 of the National Internal Revenue Code
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FREQUENTLY ASKED QUESTIONS
1) What is a Computerized Accounting System (CAS)?
It is the integration of different component systems to produce computerized Books of Accounts and computer generated accounting records and documents. (RMO 29-2002)
2) What are the components of CAS?
The components of CAS are:
a) General Journal and other subsidiary records
(Note: For General Ledger, though it is a component of CAS, taxpayer must apply for Permit to Adopt a complete CAS)
b) Sales Book, Purchases Book, Accounts Receivable Book, Accounts Payable Book, Inventory Book, Payroll Ledgers, Subsidiary Ledgers and other accounting records
c) Any application system which generates subsidiary ledger and is part of official accounting documents such as official receipts (OR), sales and cash invoices, cash vouchers, journal vouchers, billing statements, sales tickets, etc.
d) Any application system which generates reports required by the BIR (e.g. a separate report for void and suspended transactions to explain the deduction from sale, compilation of their integrated/consolidated sales report produced every end of the day); and
e) Point of Sale (POS) Machine/Cash Register Machine (CRM) connected to a network or linked to CAS. (RMO 29-2002)
3) Who are required to apply for a Permit to Adopt CAS or Components Thereof?
a) Taxpayers who will use/adopt:
· A complete CAS
· Any or some of the components of CAS
· e-Invoicing System
b) Taxpayers with valid permits to adopt CAS or component/s thereof but made systems enhancement/modification that result to change in system release and/or upgrade in version number. (RMO 29-2002)
4) Who shall apply for permit to use CAS or components thereof if taxpayers’ consultants provided the system?
Taxpayers whose CAS are provided by their consultants (e.g. accounting firms) shall apply for a separate permit for the use thereof. (RMO 29-2002)
5) In cases of affiliated companies, sister companies, franchisees and closely held corporations, who shall apply for Permit to Use CAS or Components thereof?
Affiliated companies, sister companies, franchisees and closely held corporations shall secure separate permits for the use of CAS at LTAD I or II, LTDO or RDO. This requirement is without regard whether they are sharing a server and using exactly the same system previously approved for use by its mother company or other sister companies. (RMO 29-2002)
6) Where should taxpayers apply for permit to adopt CAS or components thereof?
All applications for CAS or components thereof whether by Head Office or Branches shall be filed by the Head Office at the Large Taxpayer Assistance Division (LTAD) I or II, Large Taxpayer District Office (LTDO) and Revenue District Office (RDO) having jurisdiction over the taxpayer’s Head Office except in the following cases:
· In case the branch adopts CAS ahead of the Head Office, the application shall be filed by the Branch with the RDO having jurisdiction over the branch with a certification that the Head Office does not use a CAS. In the event that the Head Office later adopts the same CAS and the branch with a previously issued permit shall be linked to it, the permit to be issued to the Head Office shall include a new permit for the said branch, which shall supersede the previously issued permit.
· In case the branch adopts a different CAS from that of its Head Office, it shall apply for permit to adopt CAS at the BIR office having jurisdiction over the branch (RMO 29-2002)
7) When should the application be filed?
The application for permit to use CAS should be applied before the system is used or the enhanced system is adopted.
8) What are the documents required to be submitted in applying for Permit to Use CAS?
· Accomplished BIR Form 1900 and/or BIR Form 1907
· Photocopy of BIR Certificate of Registration
· Photocopy of Previously Issued Permit, if applicable
· Photocopy of Current Registration Fee Payment
· Location map of the place of business
· Inventory of previously approved unused invoices and receipts, if applicable
· List of branches that will use CAS, if any
· Application Name and Software used (Development and Database)
· Functions and Features of the Application
· System Flow/s
· Process Flow
· Sworn Statement & Proof of System Ownership
· Back-up Procedure, Disaster and Recovery Plan
· List of Reports and Correspondences that can be generated from the system with their description, purpose and sample lay out
· Facsimile of System Generated Loose-leaf Books of Accounts and List thereof, Receipts/Invoices
· Photocopy of previously issued permit of mother/sister company, another branch using the same system, if applicable
· Certification from Computerized System Evaluation Team (CSET) which previously evaluated the approved system, if applicable (RMO 29-2002)
9) Is the CSET limited to the requirements indicated in the checklist stated in RMO 29-2002?
As a general rule, yes, provided that CSET shall be allowed to ask for additional requirements if the need arises during a system demo or upon evaluation of the application. Provided further, that the taxpayer shall submit the additional requirements within the required period to process the application otherwise, the same shall be denied.
10) Will the BIR issue a temporary permit for the use of CAS?
As a general rule, no temporary permit to adopt CAS shall be issued except upon approval of the Deputy Commissioner for Operations Group. Temporary permit shall be issued only based on valid and meritorious cases (e.g., systems enhancement that need to be done abroad)
The validity of temporary permit approved by the Deputy Commissioner of Operations may either be shortened or renewed depending on the compliance on the reason(s) for issuance of the temporary permit by the taxpayer. (RMO 29-2002)
11) After filing the application, when will the Permit to Adopt CAS and/or Components Thereof be issued?
Application not requiring systems demo and no cross RDO evaluation 10 days
Application not requiring systems demo with cross 20 days
Application requiring systems demo with no cross 30 days
Application requiring systems demo with cross 40 days
RDO evaluation (RMO 29-2002)
12) In case there is an open case, would the issuance of permit be allowed?
Existence of open cases (stop-filer (RCS) cases, audit cases, accounts receivable (AR) cases, etc.) in the name of the applicant-taxpayer should not be a hindrance to the issuance of the permit to use CAS and/or Components thereof.
13) Will BIR hold the issuance of permit in case the taxpayer has a penalty payable, pending collection or audit case?
No, the collection of the penalty or pending collection or audit case is not a condition precedent in the issuance of permit.
14) In case there is a transfer of application to adopt CAS of the taxpayer from one district to another, who shall issue the permit to adopt CAS?
In case the evaluation on the application for permit to adopt CAS or components thereof requires a system demonstration, the RDO that performed the system demonstration shall issue the permit to adopt CAS or components thereof. Otherwise, if system demonstration was not yet conducted, the application including the corresponding documents submitted should be forwarded to the transferee RDO within five (5) days upon receipt of notice of transfer who shall then continue the processing of the application. The period to process shall start as day one (1).
In cases where system demonstration is not required, the originating office where the application for CAS was submitted shall issue the permit if at least 80% of the required period (10, 20 days whichever is applicable) to process/issue the permit has been consumed. Otherwise, the permit shall be issued by the transferee RDO.
15) In cases of applications for permit requiring Cross-RDO evaluation, who shall coordinate?
The CSET of the BIR office where the application was filed shall co-ordinate with the CSET of the other concerned BIR Office in case of evaluation of application involving branch within the jurisdiction of other office.
16) What is e-Invoicing (Electronic Invoicing System)?
The electronic invoicing system or e-Invoice System refers to the system developed and maintained by the e-Buyer or e-Seller or both in issuing invoice electronically through the Internet.
E-Invoice shall include sales invoice, official receipt, billing invoice, debit/credit notes or such other similar accounting documents issued electronically through the internet.
17) Is Authority To Print (ATP) Receipts/Invoices still required if the taxpayer adopts CAS?
Yes. In case of systems downtime, taxpayer shall be required to use pre-printed receipts and invoices with ATP which shall not exceed one thousand (1,000) sets or issue its remaining receipts/invoices out of the inventory of previously approved unused manually printed receipts and invoices. Also, in cases wherein the taxpayer’s system cannot generate official receipts and invoices and the like, ATP shall be applied following RMO No. 28-2002. (RMO 29-2002)
18) In cases where taxpayers do not qualify under the guidelines on RR No. 10-99 and RMO No. 29-2002, what guidelines shall be imposed?
Applications for permit that do not qualify in either issuance shall be elevated to CSET for proper evaluation and necessary recommendation.
19) Is the manual cash register machine sales book still to be maintained in case the taxpayer adopts CAS?
Taxpayer with approved CAS capable of generating reports such as but not limited to daily sales, accumulated sales, etc. need not be required to maintain manual Cash Register Machine Sales Book provided that all information required in the manual CRM Sales Book are reflected in the computerized reports.
However, these computerized reports shall be made available during post system evaluation of CAS, or duly authorized tax audit of taxpayer’s records. (RMO 29-2002)
20) What are the procedures in the application/approval of the range of serial numbers to be used for computer-generated receipts and invoices?
Taxpayers shall be required to fill up BIR Form No. 1907 in applying for the initial range of serial numbers of computer-generated invoices/receipts which shall be issued.
For the 2nd and succeeding range of serial numbers to be issued in the generation of invoices/receipts using a Global/National System of Environment, the following procedures shall be followed:
a) Taxpayers with approved CAS adopting a Global/National System shall be required to fill up Annex “A” (Application for Authority to Use the Range of Serial Number in Generating Invoices/Receipts for a Global and National System of Environment) for the succeeding range of serial numbers to be issued in generating computerized invoices/receipts;
b) The properly accomplished Annex “A” shall be submitted to the TSS of the BIR office having jurisdiction over the taxpayer’s principal place of business;
c) The TSS shall receive the properly accomplished Annex “A” and evaluate the succeeding range of serial numbers to be issued in generating invoices/receipts; and
d) After evaluation, the TSS shall prepare a Letter of Approval for the Range of Serial Numbers to be Used in Generating Invoices/Receipts in a Global/National System Environment (Annex “B”) for signature of approving official and shall issue it to the taxpayer.
21) Are taxpayers with Global System and using invoices and receipts printed abroad, required to seek advance approval of the range of serial numbers for said invoices/receipts?
No, taxpayers with Global System and using invoices and receipts printed abroad (BIR Ruling No. DA 295-98) shall not be required to seek advance approval of the next set of pre-approved range of serial number for use in the Philippines but shall present the pre-numbered invoices and receipts to BIR concerned office for registration prior to their use. The invoices/receipts herein referred to shall be tracked using office automation tools of the BIR Office.
For global system under which invoices and receipts are system-generated, the serial number of invoices/receipts issued or used during the year shall be stated/presented in chronological sequence of issuance by date of issue in the CD-ROM that will be registered, together with other accounting records, with the BIR Office having jurisdiction over the taxpayer within 30 days following the end of the accounting period.
The taxpayer shall also submit a report on the range of serial numbers of receipts and invoices which have been consumed and/or cancelled during the immediately preceding taxable year to the concerned office within 30 days from the close of the taxable year (RMO 29-2002).
22) Is the taxpayer adopting a CAS required to maintain a hardbound computer generated books of accounts, receipts and invoices and other accounting records and have them stamped?
The requirement of binding and stamping of a hardbound computerized books of accounts, receipts and invoices and other accounting records shall no longer be necessary provided that the taxpayer shall submit an Affidavit on the Post Reporting Requirements for CAS in Lieu of Hardbound Computer Generated Books of Accounts, Receipts and Invoices and other Accounting Records/Documents (Annex N of RMO 29-2002) and a soft copy in text file format of the books of accounts and other accounting records in CD-ROM properly labeled with the name of taxpayer, taxable year and serial no. and volume no. of the books of accounts and other accounting records, within 30 days from the close of the taxable year.
However, in case the taxpayer has no capability to submit in CD-ROM form, procedures under the manual system shall prevail.
23) Where does a taxpayer with a permit to use CAS, register his books of accounts and submit other accounting records?
The taxpayer shall register with the LTAD I or II, LTDOs or RDOs having jurisdiction over the principal place of business of taxpayer.
24) Are taxpayers with web-enabled electronically generated receipts/invoices (e.g. payment through credit card, payment through ATM and other similar web-enabled electronically operated receipts/invoices) required to secure permit to adopt CAS?
Yes, taxpayer with web-enabled electronically generated receipts and invoices are required to secure permit to adopt a complete CAS.
25) Who shall conduct the post system evaluation of the approved CAS of a branch?
The CSET of LTAD I or II, LTDO or RDO having jurisdiction over the Head Office of the branch shall conduct the post system evaluation of the approved CAS, provided that there should be proper coordination with the concerned CSET having jurisdiction over the branch.
26) If during the Post System Evaluation, the CSET members discovered that the taxpayer is using a system other than that of the approved CAS or a modified version of the approved CAS, would the recommendation for revocation of permit be final?
Yes, the revocation of the previously approved permit to use CAS shall be final and executory. Hence, it is mandatory for the taxpayer to apply for a new permit.
27) Shall the CSET members be allowed to conduct post system evaluation in case taxpayers modify/enhance its CAS?
The CSET shall have the authority to conduct post system evaluation through a Mission Order that shall be secured prior to its conduct.
28) What shall be the alternative course of action by CSET members in case the taxpayer prohibits them to check into its server during the post system evaluation?
The CSET members shall report the taxpayer to the Legal and Enforcement Service, Attention: Tax Fraud Division.
29) Is the six (6) – month period of interval from the date of approval of permit required before the CSET can conduct post system evaluation?
There is no required period of interval to post evaluate the approved CAS of the taxpayer. The CSET can conduct post system evaluation of the approved CAS as the need arises.
30) What are the guidelines/procedures for stamping the CDs of books of accounts and other accounting records submitted by the taxpayer?
Taxpayer Service Section (TSS) shall:
a) Check if the CD is properly labelled (using the Checklist for checking CD Annex “C”) in permanent ink with name, TIN, taxable year and the serial number and volume number of the books of accounts and other accounting records/documents;
b) Scan the CD using the prescribed virus scan utilities (it should be virus free);
c) Get the file size (in case there are two (2) or more file for a month, it should be properly labelled as volumes 1, 2, etc. of that particular month etc);
d) Open the file using any text editor (example: WordPad, Notepad, etc.);
e) Check the validity of the content of the file (it should be on a monthly basis and in a text file format.)
f) If CD passes the check criteria, stamped the CD “Registered” with a permanent ink and affix the signature of the BIR employee and the date
g) Return duly stamped CD to the taxpayer.
However, if any of the above requirements is not satisfied, return the CD to the taxpayer with the CD Checklist indicating the reason for rejection.
31) What are the responsibilities of TSS in receiving the CD?
The TSS shall be responsible in the following:
a) Ensure that they have the latest version of the virus signature;
b) Raise all technical issues relative to the submission of the CD which should be forwarded to RDC – Helpdesk;
c) Monitoring the issues raised;
d) Keep the CD checklist for future use.
32) What is the difference between cash receipts and invoices under CAS and loose-leaf receipts/invoices under the manual system?
As long as the contents of the receipts/invoices, in accordance with Sections 237, 238 and 113 of the Tax Reform Act of 1997, are generated by the system, taxpayer’s receipts/invoices shall be considered under CAS.
Loose-leaf receipts/invoices under the manual system shall refer to invoices/receipts that are not generated by CAS or components thereof. Hence, the CRM/POS machines not linked to CAS used to generate receipts/invoices shall adhere to the provisions of Revenue Regulations No. 10-99.
33) Is it necessary for the RDO having jurisdiction over the branch that adopts a CAS to issue a certification of the last serial number of Sales Invoice/Receipt consumed/cancelled?
The RDO having jurisdiction over the branch is not required to issue a certification of the last serial number of Sales Invoice/Receipt consumed /cancelled. Instead, the Taxpayer shall inform the BIR Office having jurisdiction over the branch by accomplishing Annex “M” of RMO No. 29-2002 (Report of the Range of Serial Numbers of Receipts and Invoices Consumed/Cancelled). (RMO 29-2002)
34) Is modification of header of receipt allowed? Is modification of the header of accounting reports allowed?
Modification of header of receipt shall be allowed provided that the taxpayer shall follow the provisions of Sections 237 and 238 of the NIRC of 1997.
Modification of report header is allowed which shall depend on the taxpayer’s nature of business. Provided however, that it should comply with Sec 232 of the NIRC and its implementing Bookkeeping Regulations and other related issuances.
35) In cases of taxpayers adopting an Off The Shelf CAS, would there be a need to evaluate and conduct Demonstration of the system?
In case there is prior evaluation and approval of an Off The Shelf CAS, hence a precedent application, the system shall not undergo systems demonstration in its evaluation. Provided that the Off the Shelf CAS has not been customized in any manner.
In this regard, a list of approved off-the-shelf CAS shall be monitored and provided by Information System Group (ISG) to all the CSET members through a technical bulletin for proper reference.
36) What is the jurisdictional limitation of the divisions under Large Taxpayer Service in the issuance of permit to use CAS or components thereof?
LTAD I or II and LTDOs, are authorized to issue permit to use CAS or components thereof of branches of identified taxpayers of LTAD I or II and LTDOs nation-wide. Provided however, that the concerned RDO where the branch(es) is(are) located shall be properly notified and necessary coordination shall be made.
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