With the influx of Chinese workers in the country, a lot of noodle establishments have sprouted in the central business districts. Makati, where my law office is located, is no exception. Lunch break is a perfect time for me to scout the neighborhood for any new noodle house.

Of all the noodle dishes, I am partial to stir-fired noodles, or pancit guisado. There is this noodle house along the walkway spanning Greenbelt to Makati Medical Center, in the middle of Paseo de Roxas and V.A. Rufino Street, where it serves a mean pancit guisado. I would daresay it’s the best pancit guisado I’ve tried. So naturally, I frequent this noodle house almost every week.

The place is packed at lunch time, and you will see a long queue mostly made up of which I assume to be Chinese workers. The person manning the cash-register machine (CRM) is a Chinese grandmother, the better for her to take the orders of the Chinese workers. When it’s my turn to order, I have to resort to pointing to a picture of the pancit guisado dish (it’s called “fried beef noodle”) on their menu, as she doesn’t understand any English.

As always, being a responsible taxpayer, I ask her to input and record the sale in her CRM. I blurt out the word “receipt” and try to mimic the sound of the official receipt (OR) being printed out by the CRM. She responds by giving me a puzzled look, and resorts to calling out one of their Filipino staff to help me out. It turns out that she doesn’t even know how to operate the CRM; it’s the Filipino staff that records the sale in the CRM. And this happens every single time I’m there. And as I’m there almost every week, they’re probably thinking I’m this weird guy who always asks for an OR.

Lately, while waiting for my order, I decide to go over this rare and precious OR and check the details printed on it. The bottom of the OR reads: “This invoice/receipt shall be valid for five years from the date of the permit to use.” The “date issued” indicates Dec. 11, 2013, while the “valid until” shows July 31, 2019. Five years from the date of issue should have been Dec.10, 2018, not July 31, 2019.

It turns out that under Revenue Memorandum Circular (RMC) 36-2018, invoices/receipts issued by CRMs that have been accredited by the BIR on or before July 31, 2015 shall be valid until July 31, 2020. In fact, RMC 36-2018 was recently amended by RMC 107-2019. Now, the validity of invoices/receipts issued by CRMs and other receipt-generating machines will depend on when the permit to use (PTU) was issued. If the PTU was issued before Aug. 1, 2020, the invoice/receipt shall be valid until July 31, 2025. For those issued on Aug. 1, 2020 onward, the invoice/receipt shall be valid for five years from the actual date of issuance.

Now here’s the odd part: for PTUs that were issued before Aug. 1, 2020 (which is practically all CRMs and other receipt-generating machines), the RMC requires that the invoices/receipts reflect the “date issued” as Aug. 1, 2020 and the “valid until” as July 31, 2025.

A clear case of time-traveling receipts, if you ask me. Try wrapping that around your head as I wolf down my pancit guisado.

Ron Arriesgado is a tax lawyer, a transfer pricing specialist, and is a Partner at the LMA Law Offices in Makati City. He has managed and resolved taxation issues of local and multinational entities; resolved various tax assessment cases issued by the Bureau of Internal Revenue; and provided clients with the proper tax strategies to cancel or substantially lower tax assessments, among others.

Manila Times Source