Business World

The Computeriz­ed Accounting System applicatio­n saga

- MICHELLE V. PALMA OPINION MICHELLE V. PALMA is a Senior Associate at the Client Accounting Services group of Isla Lipana & Co., the Philippine member firm of the PwC network. (02) 845-2728 michelle.v.palma@ph.pwc.com

Once a newly-establishe­d business is registered with the Securities and Exchange Commission (SEC), it must subsequent­ly register with the Bureau of Internal Revenue (BIR) and secure a tax identifica­tion number (TIN). In addition, it must register books of account for record-keeping of transactio­ns which will be used as the basis to compute its internal revenue taxes.

The first ever local regulation­s on bookkeepin­g is Revenue Regulation­s V-1 (RR V-1), also known as the “Bookkeepin­g Regulation­s,” issued in 1947. Since then, various revenue regulation­s amending RR V-1 were subsequent­ly passed to keep abreast with corporate practices and global developmen­ts. Among these is Revenue Memorandum Circular No. 13-82, providing procedures for the issuance of a permit to use loose leaf books of account, records, invoices and receipts. The BIR issued this circular, presumably, to address the clamor of Philippine companies which were required to adopt the accounting system of their foreign headquarte­rs. Nonetheles­s, manual bookkeepin­g remained the primary method of maintainin­g accounting records.

However, at the turn of the millennium, the technology boom paved the way for more efficient encoding of data through standardiz­ed digital programs and processes, especially in accounting and finance. This ushered in the use of the Computeriz­ed Accounting Systems (CAS).

In Revenue Memorandum Order (RMO) 29-2002, CAS is defined as the integratio­n of different component systems to produce computeriz­ed books of account and computerge­nerated accounting records and documents. Under the RMO, all taxpayers engaged in business are expected to apply for permits before using their CAS or its components. Applicatio­ns for CAS permits were to be filed at the Large Taxpayer Assistance Division ( LTAD) I or II, Large Taxpayer District Office (LTDO) and Revenue District Office (RDO) having jurisdicti­on over the taxpayer.

The use of a CAS without approval from the BIR will incur penalties of P25,000 on the first offense and P50,000 on the second offense pursuant to RMO 1-90, as amended by RMO 56-2000. If a taxpayer generates a sales invoice or official receipt from an unauthoriz­ed CAS, a penalty of P1,000 will be imposed for each document issued, but the maximum penalty shall not exceed P25,000 per year.

It was in the early 2000s, right after the worries generated by the so-called Y2K or Millennium bug, when CAS started to proliferat­e in the Philippine­s. Applicatio­ns for CAS were processed, evaluated, and then approved by the BIR within a time frame of two to three months.

In 2014, the BIR raised concerns on the CAS approval process at the RDO level, as some permits may have been issued without the benefit of a thorough evaluation process. This prompted the former Commission­er to issue Revenue Special Order (RSO) 581-2015, which centralize­d the evaluation, recommenda­tion, and approval processes to two Technical Working Groups ( TWG) — one for Large Taxpayers (LT) and the other for Non-Large Taxpayers (NonLT). Each group is composed of at least three personnel from the LTAD who are technicall­y equipped to evaluate the CAS and at least one examiner from the BIR off ice where the applicant is registered. With the creation of the TWGs, the evaluation and approval process at the RDO and LTDO levels was canceled.

Under the centralize­d applicatio­n process, the CAS walkthroug­h or systems demonstrat­ion is scheduled within four to six months from filing of the applicatio­n. The walkthroug­h at the applicant’s place of business takes about four to six hours to complete. Thereafter, the TWG evaluating team may provide the applicant with a list of requiremen­ts and proposed modificati­ons for improvemen­t of the CAS which the taxpayer- applicant must comply with within 30 days.

In September 2016, the BIR released a draft Revenue Regulation mandating the accreditat­ion of CAS, computeriz­ed books of account and/or its components, middleware and electronic storage systems, and issuance of the correspond­ing certificat­e of accreditat­ion and/or permit to use (PTU).

Compared to the current CAS applicatio­n process, the guidelines proposed in the draft RR are more convenient for CAS users. Once the accredited CAS is purchased from a developer, distributo­r or dealer (or simply called, “CAS Supplier”), the next step is to apply for the issuance of a PTU at the RDO level or LT level. It dispenses with the taxpayer’s walkthroug­h or systems demo, in view of the prior accreditat­ion of the purchased CAS.

The question remains whether the BIR will be able to manage the task of accreditin­g the CAS Suppliers. In the absence of an efficient implementa­tion plan, the snail’s pace applicatio­n process at the taxpayer’s level may just end up being carried over to the accreditat­ion process. That said, since there would be fewer applicatio­ns to process (assuming there are fewer suppliers than actual users), this alternativ­e should result in definite improvemen­t compared to the current scenario.

Apart from revising procedural steps, it may also be worthy for the BIR to reevaluate the current number of personnel assigned to the TWGs in order to keep up with the work load and ensure that applicatio­ns are reviewed in a timely manner. It is also necessary for the BIR to ensure that its IT personnel are receiving the appropriat­e skills training. With the constant upgrades of CAS and the increase of applicatio­ns, the tasks of the evaluating team require continuing enhancemen­t of their skills concurrent with the demands of their work.

The saga of the applicatio­n to use CAS will continue until a more efficient process is in place. The proposed regulation­s accreditin­g CAS Suppliers are a step in the right direction. With innovation showing no signs of a slowdown, there are reasons to be optimistic about the future of bookkeepin­g and CAS registrati­ons.

The views or opinions in this article are solely those of the author and do not necessaril­y represent those of Isla Lipana & Co. The firm will not accept any liability arising from the article.

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