Summary List of Purchases (SLP) and Summary List of Sales (SLS) submission has long been prescribed under Revenue Regulations No. 7-95 and was adopted by Revenue Regulations No. 16-2005 – The Consolidated VAT Regulations (RR 16-05), as amended, for VAT-registered taxpayers under the following parameters:
For the purpose, an electronic facility called a RELIEF (downloadable from the BIR website)has been devised by the BIR and prescribed to be used in encoding the required details from the official receipts and sales invoices.
Consequences of Failure to Comply
Failure to submit the required SLS and SLP is punishable as follows:
In sum, if you do not comply, then you will be sanctioned up to the maximum of P25,000.00 a year of administrative penalty or worst, you could go to jail for the same. On top of it, you will still be required to comply because payment of penalty will not excuse you from non-compliance.
How the BIR uses the SLS and SLP
Data generated from this SLS and SLP is used by the BIR in matching of sales and purchases from among the taxpayers so the same has been a source of numerous tax assessments and deficiency internal revenue taxes. Declared sales by the seller not declared as purchases by the buyer, and vice versa is the common ground for alleged under declaration. However, with the selected taxpayers, the P2.5M and P1.5M threshold, the matching becomes deficient so many taxpayers could simply get away.
The New SLS and SLP Mandate
Looking at the loophole, Revenue Regulations No. 1-2012 was issued by the BIR to finally make the SLP and SLS a MANDATORY submission among ALL VAT-REGISTERED taxpayers regardless of the amount of the transaction. Same penalties were imposed for non-compliance therewith and hereunder are the required details:
Summary List of Sales (SLS)
- Input of required details on the quarterly Summary List of Sales with the following:
- BIR Registered name of buyer;
- T.I.N. of buyer;
- Nature of sales – Vatable, Exempt, Zero-rated and those subject to Final VAT;
- Amount of sales
- VAT amount on sales
Summary list of local purchases
- BIR registered name of supplier
- T.I.N. of seller
- Nature of purchase – Vatable, Exempt, Zero-rated and those subject to Final VAT;
- Amount of sale
- Creditable input VAT
- Non-creditable input-VAT
Summary list of importation
- Import entry declaration number;
- Assessment/release date;
- Date of importation;
- Name of seller;
- Country of origin;
- Dutiable value;
- All charges before release from BoC custody;
- Landed cost – exempt/taxable
- VAT paid;
- Official Receipt number of VAT payment;
- Date of VAT payment;
Reports to be submitted shall be system generated with totals and in alphabetical arrangement of name of suppliers/buyers in prescribed format.
How to Comply
The above mandate does not seem to require much. After downloading the program from the BIR website, the same will be installed in your computer and you could easily input the above required details in the corresponding fields provided. Submission is likewise quarterly, not later than the 25th day after the end of the quarter so so much time is available to comply.Please note that BIR is now becoming more sophisticated and more aggressive in imposing the mandates of the tax rules and regulations. It may just be a matter of time that those who do not comply will later be dealt with.
An invoice or receipt may take an average of one (1) minute to encode. We suggest that you do the encoding more frequent, e.g. daily or weekly, so they will not pile up and became hard for you to handle. If you have such volume of invoices and receipts, you may opt to hire a staff or encoder for the purpose. As an employee, you will have to pay the basic minimum wage and all other benefits mandated by law. Alternatively, if you would see it more beneficial, then, you can consider outsourcing the encoding. They could be more familiar with the details and in line with their work, they could do more efficient and accurate in the encoding and generation of reports.
Finally, compliance of summary list of sales and summary list of purchases does not do away with proper substantiation. Please bear in mind that the BIR registered VAT official receipts and invoices being encoded must still contain the prescribed information ,e.g. exact name of the business entity, address, tax identification number, and the details of sales and VAT.Even if you submit the SLS and SLP reports, the claim of input VAT on improper substantiation will still be disallowed and you will be required to pay the penalties – the basic amount, 25% surcharge, 20% interest, and the compromise penalty ranging from P200 to P50,000 depending on the basic amount.
Revenue Regulations No. 16-2005, as amended by Revenue Regulations No. 1-2012;
Revenue Regulations No. 7-95
Business Process Outsourcing. We assist VAT taxpayers in complying with the BIR required Summary List of Sales and Summary List of Purchases. We train our staffs with the required technical knowledge of the VAT requirements and they will not just encode, but will also advise whether or not the related invoices and receipts are in compliance with the VAT regulations so you could be aware of the risks and remedy the same moving forward. Please contact us for related concerns.
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