Registration of Manual of Books of Accounts

I was one who experienced the confusion and frustration in the registration of manual of books of accounts because of the different rules and procedures adopted by the different Revenue District Offices (RDOs) of the Bureau of Internal Revenue. Some RDOs, required taxpayers to first present the previously registered books of account regardless of whether or not the pages have all been filled up before a new set of books of accounts is registered. While, other district offices, a photocopy of the stamped front page of the previously registered books of account is the document required in order to approve the registration of the new set of books. 

With the misinterpretations on registration procedures, the BIR has issued the Revenue Memorandum Circular No. 82 - 2008 for the proper registration procedures for manual books of accounts based on the existing provisions in the Bookkeeping Regulations. 

The existing rules with respect to the registration of manual books of accounts is with details as follows:

(1) Manual books of accounts previously registered but whose pages are not yet fully exhausted can still be used in the succeeding years without the need of re-registering or re-stamping the same, provided, that the portions pertaining to a particular year should be properly labeled or marked by taxpayer; 

(2) The registration of a new set of manual books of accounts shall only be at the time when the pages of the previously registered books have all been already exhausted. This means that it is not necessary for a taxpayer to register a new set of manual books of accounts each and every year. 

(3) The registration deadline of “January 30 of the following year” as enunciated in RMO 29-2002 applies only to computerized books of accounts and  2 not to manual books accounts. The “15 days after the end of the calendar year” deadline under RMC 13-82 refers to loose-leaf bound books of accounts and not to manual books of accounts; 

(4) Newly Registered taxpayers shall present the Manual Books of Accounts before use to the RDOs where the place of business is located or concerned office under the Large Taxpayer Service for approval and registration; 

(5) Subsidiary manual books of accounts to be used by taxpayers, in addition to the manual books of accounts, required by the National Internal Revenue Code of 1997 and existing rules, shall likewise be registered before use, following the same rules abovementioned; 

(6) It is to be emphasized that the Taxpayer Service Section (TSS) of the RDOs or concerned office under Large Taxpayer Service has no authority to examine whether the previously registered books are complete and/or updated prior to the approval of the registration. 

The aforementioned rules are to be uniformly observed by revenue officers in charge of registration of manual books of accounts. 

Taxpayers should strictly comply with this registration requirement for books of account in order to avoid compromise penalty of P1,000 for failure to register the manual books under the revised schedule of compromise penalties.

Some companies are still registered under manual books of accounts, although they generate accounting records using computer programs or software. Printouts of such records are simply pasted in their registered manual books. The regulations are not clear whether the practice is allowed. But this instances has been questioned by tax examiners. Thus, this is also liable to penalty under the laws and regulations.

The companies and taxpayers are advised to properly register the kind of books that it actually maintains and do the good practice to avoid being exposed to penalties. 

Reference: RMC No. 82-2008; RMO No. 19-2007