BIR Rules for Amending Invoices or Receipts: Required Attachments and Legal Basis (Philippines)

Updated for general practice and long-standing rules under the National Internal Revenue Code (NIRC), as amended. Always coordinate with your Revenue District Office (RDO) for RDO-specific formats and any more recent circulars.

1) What “amending an invoice/receipt” really means

In Philippine tax practice, “amendment” happens in two very different contexts:

Transactional correction — fixing an error in a document that has already been issued to a customer (e.g., wrong amount, VAT treatment, buyer name, TIN, or the sale was cancelled/returned).
Document/series update — changing the printing particulars that appear on all your blank invoices/official receipts (business name, trade name, address, TIN, VAT status, additional line items), which requires updating your BIR authority for your invoice/receipt series (and, where applicable, your POS/CAS/e-invoicing Permit to Use).

The BIR does not allow erasures or manual overwriting on issued invoices/ORs. Corrections are done via credit/debit memos or cancellation/adjustment entries, not by altering the original.

2) Core legal bases (NIRC)

Section 113 — Invoicing requirements (what must appear; when to issue; VAT content; use of debit/credit memos to reflect adjustments such as returns, allowances, and price changes).
Section 237 — Issuance of receipts or sales/commercial invoices (mandatory issuance; minimum content; rules apply to both VAT and non-VAT taxpayers).
Section 238 — Printing of receipts/invoices (requires BIR approval/authority; unlawful printing without authority).
Section 264 — Penalties for failure to issue receipts/invoices or for using receipts/invoices that do not comply with BIR requirements.

(Various revenue regulations, memoranda and circulars elaborate on these sections—for example, on Authority-to-Print (ATP)/Permit-to-Use (PTU), content standards, and e-invoicing— but the backbone is in the NIRC provisions above.)

3) Transactional corrections: how to amend an already-issued document

3.1 Typical situations

Wrong price/quantity/discount
Wrong VAT treatment (e.g., should have been zero-rated/exempt; or VAT incorrectly added/omitted)
Sales return/cancellation (partial or full)
Wrong buyer details (name/TIN/address) that the buyer needs for input VAT or substantiation
Timing/period errors (e.g., recognized in the wrong month)

3.2 The allowed instruments

Credit Memo (CM) — reduces the gross sale/amount due and, where applicable, the output VAT. Used for returns, allowances, price reductions, and cancellation of a sale.
Debit Memo (DM) — increases the gross sale/amount due and, where applicable, the output VAT (e.g., under-billing, omitted charges).
Cancellation/Void — if discovered immediately at the point of sale (POS mis-punch, duplicate print), void the document and re-issue in the same transaction window, retaining both the voided and the corrected document in your audit trail/log.
Replacement Invoice/OR — when only non-economic details are wrong (e.g., buyer’s legal name/TIN), and the parties agree not to alter the amount or tax. Practice is to issue a replacement marked “REPRINT/REPLACEMENT — NO CHANGE IN AMOUNT/TAX; ORIG. REF: [Document No.]” and to keep the original on file (not destroyed) cross-referenced to the replacement.

Never alter the original issued invoice/OR. All changes must be traceable through a separate document (CM/DM/replacement) that references the original.

3.3 Minimum content of CM/DM

Document title (CREDIT MEMO/DEBIT MEMO) and pre-authorized numbering/series
Seller’s registered name, address, TIN, and (if VAT-registered) the “VAT Registered” legend
Buyer’s registered name, address, and TIN (if available/required by law for their claim)
Date of issue
Original invoice/OR number and date being adjusted
Reason for adjustment (e.g., “Sales return — damaged goods,” “Price adjustment per contract,” “Correct VAT status to zero-rated”)
Detailed computation: base amount, VAT rate, VAT amount, and the net change (+/–)
Authorized signatory per company policy

3.4 Accounting & VAT timing

Record the CM/DM in the period it is issued, with cross-references to the original sale.
For VAT: output VAT and sales are adjusted in the seller’s books and VAT returns for the period of the CM/DM; the buyer correspondingly adjusts input VAT/expense in that period.

3.5 Required attachments (seller’s file set)

Copy of the original invoice/OR
Copy of the CM/DM or replacement document
Commercial support proving the correction (any that apply):
- Return receipt/Receiving report for returned goods
- Approved sales return/allowance form
- Email/letter/contract proving price change or cancellation
- Buyer’s request citing correction and, if VAT-sensitive, the buyer’s Certificate of Registration (BIR Form 2303) page showing VAT status/TIN (or buyer’s sworn statement if data privacy is invoked)
- For wrong VAT treatment (e.g., zero-rated): proof of entitlement (e.g., BOI/PEZA/locators’ certifications, VAT zero-rate endorsements, foreign currency inward remittance proof for certain sales of services, customer’s VAT exemption proof), as applicable
Internal approval (credit committee/finance head sign-off)
Audit trail printout/log (for POS/e-systems) showing the original, void, and corrected entries when applicable

Best practice: compile these in a CM/DM jacket or digital folder per transaction; keep for the full BIR prescription period (generally 10 years for books/records).

4) Updating what’s printed on your blank invoices/ORs (business changes)

If your business name, trade name, address, TIN, VAT status, or other required printed particulars change, you cannot simply stamp over existing booklets indefinitely. You need to update your BIR authority (ATP/PTU) and print a new series (or update your POS/CAS/e-invoicing profiles).

4.1 Triggers that require new printing/authority update

Change in registered name/trade name or address (especially inter-RDO moves)
Change in TIN (e.g., merger/conversion creating a new TIN)
Change in VAT status (VAT ⇄ non-VAT) or additional taxes (e.g., percentage tax) affecting legends on the face of the document
Adoption/replacement of POS/CAS or migration to e-invoicing/e-receipting that changes numbering or layout
Addition of mandated legends (e.g., special economic zone or zero-rating legends required by law/regulation/contract)

4.2 High-level steps

Update registration with BIR (e.g., BIR Form 1905 for updates like address, trade name, additional taxes; and any other forms required by the change such as transfer of RDO).
Apply/Update ATP or PTU:
- Authority to Print (ATP): for printed/loose-leaf invoices/ORs (BIR Form 1906 with printer’s details, layouts, and series).
- Permit to Use (PTU) for POS/CAS/e-invoicing: update configuration, series, and legends; secure revised PTU/registration where applicable.
Print issue-specific series (or deploy the updated POS/e-invoice template) only after ATP/PTU is granted.
Inventory & disposal of unused old booklets (see 4.4).

4.3 Minimum printed content to check (spot-audit)

Registered name/trade name and address that match your Certificate of Registration
TIN and VAT legend (e.g., “VAT Registered TIN: …” and “VAT Zero-Rated” legends where mandated)
Document title (e.g., Sales Invoice, Official Receipt), pre-printed serial number, and series/format approved in ATP/PTU
Printer’s details and ATP number/date (for printed sets)
Required itemization: date, quantity/description, unit price, total, discounts, VAT amount/rate or “VAT-exempt”/“Zero-rated” annotation as applicable; buyer TIN/name lines if required for the buyer’s claim thresholds

4.4 Handling old, unused booklets after changes

Count and list all unused booklets and last used serial number.
Prepare a Sworn Statement on inventory and reason for discontinuance.
Coordinate with your RDO on disposal/cancellation (practices vary: some require witnessing/sealing, others accept an inventory plus sample leaf and commitment to keep unused sets for audit).
Keep at least one sample of the old and one of the new booklet in your permanent files, with copies of the relevant ATP/PTU.

4.5 Required attachments for ATP/PTU updates (typical)

BIR Form 2303 (Certificate of Registration)
BIR Form 1905 stamped “received” (for the registration update that triggered the change)
Sample lay-out/proof of the new invoice/OR (with all required legends)
Printer accreditation (for ATP) and proposed serial range
Taxpayer ID & valid ID of authorized signatory; Board/Partner resolution or SPA authorizing the application
Inventory of unused booklets and last used serial
For POS/CAS/e-invoicing: system description, serial number logic, audit trail description, and PTU update package with screenshots/templates
Any supporting licenses/permits that justify special legends (e.g., ecozone, BOI, diplomatic)

Your RDO may prescribe their own cover letter and annex sequencing. Follow their checklist when given; maintain a mirror copy in your statutory files.

5) Special VAT situations (zero-rating/exemption fixes)

If the original invoice/OR showed 12% VAT but the sale should be zero-rated or VAT-exempt, you usually issue a Credit Memo to reverse the VATed sale and either:

re-invoice under the proper zero-rated/exempt treatment; or
issue a net-of-VAT replacement referencing the original.

Keep documentary proof of entitlement (e.g., buyer’s VAT status certificates, PEZA/BOI documents, cross-border or foreign currency inward remittance evidence for qualifying services, government or international organization exemptions). These must be kept with the CM/DM jacket to survive audit.

6) Documentation standards & retention

Cross-reference every CM/DM/replacement to the original invoice/OR by document number and date.
Retain all originals, replacements, memos, and support for at least 10 years alongside your books and VAT returns.
Maintain sequential control over CM/DM numbers (pre-printed or system-controlled).
For electronic/POS systems, keep unalterable audit logs showing creation, void, and adjustment events.

7) What not to do (common audit findings)

Handwritten erasures/white-outs on issued invoices/ORs
Issuing a second invoice for the same sale without cancelling/credit-memorizing the first
Using old booklets after a change in VAT status, business name, or address
CM/DM without business reason or supporting documents
CM/DM issued in bulk at year-end to “fix” margins (invites disallowance)
Missing buyer TIN/name where required for the buyer’s input VAT claim thresholds
Failure to align books/returns with the CM/DM trail (amounts don’t tie to VAT schedules)

8) Penalties & risk

Under NIRC Sec. 264, failure to issue compliant receipts/invoices, or using unapproved/incorrect ones, can result in fines and criminal penalties; repeat or willful violations risk closure under BIR’s Oplan Kandado-type programs. In audits, unsupported CM/DMs are commonly disallowed, leading to VAT and income tax assessments with surcharges and interest.

9) Practical checklists

9.1 Correcting an issued invoice/OR (amount/VAT error)

☐ Prepare CM (for reductions) or DM (for increases)
☐ State reason and original doc no./date
☐ Attach support (return receipt/contract/email; buyer evidence if VAT-sensitive)
☐ Post to books/VAT for the current period
☐ Provide buyer a copy; secure acknowledgment if it affects their VAT

9.2 Correcting buyer’s non-economic details (name/TIN)

☐ Issue Replacement/Reprint marked as such; no change in amount/tax
☐ Cross-reference original; keep both on file
☐ Attach buyer request and their TIN evidence (or sworn statement)

9.3 Updating printed particulars (business changes)

☐ File BIR Form 1905 (and other registration forms as required)
☐ Apply for ATP (BIR Form 1906) or PTU update (for POS/CAS/e-invoicing)
☐ Print/deploy new series after approval
☐ Inventory & arrange disposal/cancellation of old unused booklets
☐ Keep sample old/new sets with ATP/PTU copies in permanent file

10) Template language you can adopt

Credit Memo reason line (examples):

“Price adjustment per Sales Contract Addendum dated [date]. Adjusts SI [no.] dated [date].” “Sales return due to defects, RR No. [no.] dated [date], per QA report attached.” “Correction of VAT treatment to Zero-Rated pursuant to [legal basis] for sales to [PEZA/BOI/foreign] buyer; see attachments.”

Replacement invoice header legend:

“REPLACEMENT COPY (NO CHANGE IN AMOUNT/TAX) — replaces SI/OR No. [no.] dated [date] issued to [buyer]. Original retained on file.”

11) Frequently asked edge cases

Customer wants a completely “new” invoice with the same number. Not allowed. Numbers are sequential and immutable once issued. Use a replacement copy (no amount/tax change) or CM/DM plus a fresh invoice if the economics changed.
POS mis-punch noticed after day-end. Cannot use the “void” function for a prior closed batch. Issue a CM/DM referencing the original and document the operational lapse.
Service provider using Official Receipts (ORs) but contract says “invoice.” Document title does not override tax rules. Ensure your document type and VAT content comply with Sec. 113/237; if you migrate to “invoice-only” practice, align with BIR guidance and your registration (and, if needed, update ATP/PTU).
E-invoicing participants (e.g., large taxpayers) who changed templates. Update your PTU/e-invoice profiles, maintain audit logs of versioning, and keep mapping documentation that ties old to new fields and number series.

12) Final compliance tips

Treat every correction as audit-facing: tell the story with documents.
Keep a matrix that maps original invoices/ORs to every CM/DM/replacement issued.
Standardize reasons; disallow vague phrases like “others.”
Train frontliners on when to void vs. when to CM/DM.
Reconcile monthly: VAT relief/sales journals must match CM/DM registers and BIR returns.

Bottom line

You never alter an issued invoice/receipt. You amend it by issuing a credit/debit memo or a replacement that cross-references the original, with full documentary support. When the business particulars change, you update BIR registration and your ATP/PTU, then print/deploy a new series and properly retire the old. The controlling law is in NIRC Secs. 113, 237, 238, and 264, with procedural details implemented through BIR’s regulations and RDO checklists—so always align your file set with what your RDO asks for.