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On the registration of manual books
Lets Talk Tax
BusinessWorld, 13 January 2009
By: Marietta B. Saludaga





Compliance with the requirement for registration of books of accounts is not as simple as it
seems.
It has been a source of confusion and frustration among taxpayers because not all revenue
district offices (RDO) adopt similar rules. Some RDOs apply different procedures.
Certain RDOs require taxpayers to present previously registered manual books, whether
fully used or not, as a prerequisite for the registration of a new set of books. In other RDOs,
what is required is a copy of the front pages of the registered books that the BIR stamped
when it was previously registered.
To simplify the registration of manual books of accounts and establish uniform procedures,
the Bureau of Internal Revenue (BIR) recently issued Revenue Memorandum Order No.
(RMO) 82-2008.
Under the said issuance, the BIR clarified that manual books of accounts that have been
registered by a taxpayer but have not yet been fully utilized can still be used in the succeeding
years without the need for restamping.
However, it is required that the pages applicable to a particular period should be labeled for
proper monitoring. A new set of books shall be registered only when the previously
registered books have been fully utilized.
Taxpayers, therefore, are not required to register a new set of books every year.
Also, in accepting new books for registration, the revenue officer has no authority to
examine whether the previously registered books are complete or updated.
These new rules provide relief to taxpayers, who can now use the remaining pages of manual
books without having them restamped or going through the hassle of presenting previously
registered books for registration purposes. It is likewise extended to revenue officers
responsible for registration and monitoring compliance.
This issuance shows the relentless efforts of tax authorities to improve existing tax rules.
However, such improvement can be realized and appreciated by taxpayers only if the
concerned revenue officers will be apprised of this new rule and implement it accordingly.
There is no specific deadline for registration mentioned under the issuance. Since it is
required that the registration of manual books of accounts be made prior to their use, a new
set of books can be presented for registration as the need arises. The RMO specifies that the
same rule applies both to newly registered taxpayers and existing registered taxpayers.
The other registration deadlines mentioned in previous BIR issuances are many times
confused as the deadline for the registration of manual books. There are instances when
taxpayers are penalized by some RDOs for not meeting deadlines with respect to their
manual books.
The RMO points out that the registration deadlines, which are "January 30 of the following
year" under Revenue Memorandum No. 29-02 and "fifteen (15) days after the end of the
taxable year" under Revenue Memorandum Circular No. 13-82, apply to computerized
books of accounts and loose-leaf books of accounts, respectively.
These deadlines do not apply to manual books of accounts.
Thus, taxpayers maintaining manual books should refuse the payment of penalty if these are
imposed for not meeting these registration deadlines that are applicable for loose-leaf books
and computerized books.
Just like any other registration, it should be made in the RDO having jurisdiction over the
business of the taxpayer. In the case of large taxpayers, the venue shall be the concerned
office under the Large Taxpayer Service. Taxpayers should strictly comply with this
registration requirement for books of accounts in order to avoid the imposition of
corresponding penalty. Under the revised schedule of compromise penalties, failure to
register the manual books shall be liable to P1,000 compromise penalty.
In addition to registering their books, companies should also evaluate the exact nature of the
books of accounts that they actually maintain. Some companies are still registered under
manual books of accounts, although they generate accounting records using computer
programs or software.
In certain cases, printouts of such records are simply pasted in their registered manual
books. The regulations are not clear whether that is allowed. This practice has, in certain
instances, been questioned by tax examiners. In extreme cases, the registered manual books
remain unutilized because the records are actually being maintained in the computers. This is
also liable to penalty under the laws and regulations. Some examiners simply refuse to
recognize such accounting records during examination.
The company, therefore, is well-advised to properly register the kind of books that it actually
maintains. It is always a good practice so as to avoid being exposed to penalties.
(The author is a tax manager at Punongbayan & Araullo, a member firm within Grant
Thornton International Ltd. For comments and inquiries, please e-mail
Marietta.Saludaga@pna.ph or call 886-5511.)