June 15, 1998

BIR RULING NO. 093-98

RR 2-90 238-000-00-093-98

Everlasting Import-Export Corporation

Breeding Farm, Sahud Ulan

Tanza, Province of Cavite

Attention: Mr. Sang Doo Lee

Vice-President

Gentlemen :

This refers to your letter dated October 27, 1997 requesting for a ruling as to whether or not an
unregistered receipt and a copy of a lease contract can be used as legal supporting documents for your
rental expense and or input VAT. prLL

In reply, please be informed that Revenue Regulations No. 2-90 dated May 25, 1990 re: Restoring the
requirement to register and stamp receipts and invoices prior to their use, in relation to Section 238 of
the Tax Code of 1997 (then Section 239 of the Tax Code of 1977, as amended) provides that —

"SEC. 2. . . .

"(d) Registration and stamping of receipts and invoices.

Before being used, the printed receipts, sales or commercial invoices shall be registered with the
revenue district officer where the principal place of business of the taxpayer is located within thirty (30)
days from the date of printing the same. The registration of the printed receipts or invoices shall be
evidenced by an appropriate stamp on the face of the taxpayer's copy of the authority to print as well as
on the front cover, on the back of the middle invoice or receipt and on the back of the last invoice or
receipt of the registered booklet or pad, authenticated by the signature of the officer authorized to
place the stamp.

"SEC. 3. Unused or unissued receipts and invoices in the possession of the taxpayers and have been
printed prior to the effectivity of these regulations must also be registered with the Revenue District
Office where the principal place of business of the taxpayer is located within thirty days from the
effectivity of these regulations."

Accordingly, for tax purposes, all receipts and invoices must be duly registered with the Revenue District
Office where the principal place of business is located. The registration of the same is evidenced by an
appropriate stamp on the face of the taxpayer's copy of the authority to print as well as on the front
cover, on the back of the middle invoice or receipt and on the back of the last invoice or receipt of the
registered booklet or pad, and duly authenticated by the signature authorized to place the stamp.
Absence of the required appropriate stamp is prima facie evidence that the receipts and invoices are not
registered. Hence, they cannot validly support your claim for any legitimate expenses or input VAT
relating to the purchases made. llcd

Very truly yours,

(SGD.) LIWAYWAY VINZONS-CHATO

Commissioner of Internal Revenue