BIR Registration of Manual Books: Things you don’t know might hurt you.

The Bureau of Internal Revenue issued a Revenue Memorandum Circular 82-2008 to simplify the registration of manual books of accounts and to establish uniformity of procedures among the BIR district offices.

It has been observed that the different Revenue District Offices (RDOs) of the Bureau adopt differing rules and procedures with respect to the registration of the manual books of accounts. In some RDOs, before a new set of books of accounts is registered, taxpayers are still required to first present the previously registered books of accounts regardless of whether or not the pages thereof have all been filled up. On the other hand, in other districts, a photocopy of the stamped front page of these previously registered books of accounts is the document being required in order to approve the registration of the new set of books. Apparently, these differing rules observed by the RDOs have caused frustration and exasperation to the taxpayers which eventually resulted to an indifferent attitude towards compliance.

Despite of the issuance of the RMC 82-2008, many taxpayers are still unaware of the provisions of the memorandum circular. Infact, even the personnel of the Bureau are not implementing its own set of rules or circular. We have observed, only this January 2013, that the BIR personnel incharge of the verification of TIN expressly telling to the taxpayers that they have not yet registered its books and were instructed to pay a penalty for its late registration of the manual books.

It is very frustrating to observe or learn that taxpayers were being imposed with unnecessary penalties just because of being ignorant to their rights with regards to the registration of their manual books of accounts. But it is also the responsibility of the government to impose only just and rightful fines and penalties to the taxpayers if they were not really compliant to the rules imposed by the Bureau.

The excerpts of the RMC 82-2008 in a bullet presentation are as follows:

1. Taxpayers are not required to register a new set of books every year unless all pages were fully utilized.
2. The revenue officer has no authority to examine whether the previously registered books are complete or updated.
3. There are no deadlines of registering the manual books of accounts, but the manual books of accounts should be registered before it is used.

The BIR issuance of the RMO 82-2008 has been greatly appreciated by most taxpayers, public practitioners, and tax consultants who are aware of the provisions stated therewith. This  has provided  relief for those who know about the provisions of the memorandum circular. At least, taxpayers has the weapon to contest or protest any unjust imposition of penalties by the Bureau in cases of late registration of the manual books of accounts. But, mere issuance of the Bureau of the RMC is WORTHLESS without the proper implementation of its rules and regulations.

It is advised all taxpayers to know their rights to defend themselves against the incompetent, unjust and unscrupulous  practices of some of the government personnel. This is also a wake-up call to the responsible officials to let them implement rightfully the imposition of their charges to the taxpayers.