How to Record Wet Market and Palengke Purchases as a Business Expense (No Receipt)

A wet market or palengke vendor selling you ₱300 worth of vegetables usually isn’t required to hand you an invoice — NIRC Section 237, as amended by the Ease of Paying Taxes (EOPT) Act, only requires a non-VAT-registered seller to issue one once a single sale reaches ₱500 or more. That’s good news for the vendor and bad news for a carinderia or catering business trying to substantiate the purchase as a deductible expense. The fix isn’t waiting for a receipt that may never come — it’s building your own substitute record at the point of purchase.

Why doesn’t the market vendor issue a receipt in the first place? #

Under NIRC Section 237 as amended, a seller who isn’t VAT-registered only has to issue a duly registered invoice once the transaction hits the statutory threshold — currently ₱500 — or when the buyer specifically requests one, regardless of amount. The amended provision reads:

“All persons subject to an internal revenue tax shall, at the point of each sale and transfer of merchandise or for services rendered valued at Five hundred pesos (P500) or more, issue duly registered sale or commercial invoices…” — NIRC Section 237, as amended by Section 35 of RA No. 11976 (the EOPT Act)

That threshold is why a typical palengke transaction — a kilo of bangus, a bundle of kangkong, a tray of eggs — often falls below the line where the law compels the vendor to issue anything at all. Revenue Regulations No. 7-2024 also clarifies that transactions below ₱500 must be aggregated within the day, and once that daily total crosses ₱500, an invoice is required for the aggregate. A VAT-registered seller doesn’t get this exception — they must issue an invoice for every sale, any amount. The ₱500 figure isn’t fixed forever, either: the EOPT Act requires the BIR to adjust it for inflation every three years using the Consumer Price Index, starting January 22, 2024.

So how do you still deduct the purchase without a receipt? #

The vendor’s exemption from issuing an invoice doesn’t exempt the buyer from NIRC Section 34(A)(1)(b)’s substantiation requirement — you still need “official receipts or other adequate records” to claim the deduction, even if the law never required the seller to give you one. In practice, that means building your own record at the moment of purchase:

1. Keep a purchase log or self-prepared acknowledgment receipt. Note the date, the vendor’s name or stall number, the items, and the amount, and — where possible — have the vendor sign or initial it.
2. Pay electronically where the vendor accepts it. A GCash or Maya transfer confirmation, or a bank transfer record, independently corroborates the amount and date without relying on the vendor at all.
3. Photograph the goods and the transaction context if useful, especially for larger recurring purchases — a dated photo of delivered produce alongside your purchase log strengthens the record.
4. Post it consistently to your books — a purchase journal or cash disbursement book — so the substitute record isn’t a one-off but part of your regular accounting records, which is part of what the BIR looks for when it evaluates “other adequate records” under Section 34(A)(1)(b).

A worked example: a carinderia owner sources vegetables daily #

A carinderia owner buys roughly ₱350 worth of vegetables and spices each morning from the same palengke vendor, paid in cash, no receipt issued — the transaction sits below the ₱500 threshold, so the vendor isn’t violating Section 237 by not issuing one. To substantiate the expense, the carinderia owner keeps a simple daily purchase notebook: date, vendor’s stall name, items bought, and total amount, with the vendor initialing each entry as a running informal tab. At month-end, the 30 entries total ₱10,500 in vegetable purchases, each one dated, itemized, and acknowledged by the same identifiable vendor — a record that gives an examiner both elements Section 34(A)(1)(b) asks for: the amount, and its direct connection to running the carinderia’s kitchen.

What if you specifically ask for a receipt and the vendor won’t give one? #

Section 237 gives a buyer the right to demand an invoice regardless of the transaction’s peso amount, and a registered seller who refuses that specific request is out of compliance — that’s a different situation from a vendor simply not volunteering one on a small, unrequested sale. For your own deduction, though, the practical answer is the same either way: keep building your own substitute record rather than treating the refusal as a dead end. For the fuller picture of what changed in Philippine invoicing generally, see Invoice vs. Official Receipt: What Changed Under the EOPT Act, and for what “adequate records” means under the substantiation rule itself, see Can You Deduct Business Expenses Without an Official Receipt? BIR Rules for Sole Proprietors.

Frequently asked questions #

Is a wet market vendor breaking the law by not giving me a receipt? #

Usually not, if the sale is under ₱500. NIRC Section 237, as amended by the Ease of Paying Taxes (EOPT) Act, requires a non-VAT-registered seller to issue an invoice only once a single transaction reaches ₱500 or more, once daily sales below that amount add up past ₱500, or if the buyer specifically asks for one regardless of amount. A vendor selling you ₱250 worth of fish for the day, with no request from you for an invoice, isn’t violating Section 237 by not issuing one.

Can I still deduct a wet market purchase as a business expense without a receipt? #

Yes, if you document it another way. NIRC Section 34(A)(1)(b) lets a taxpayer substantiate a deduction with “official receipts or other adequate records” — a self-prepared acknowledgment receipt or purchase log the vendor signs, plus proof of payment such as a GCash transfer, is generally enough to support the claim even though the vendor issued nothing.

What if I ask the vendor for an invoice and they refuse? #

Under Section 237, a buyer can demand an invoice regardless of the transaction amount, and the seller is legally required to issue one. If a registered vendor refuses despite a specific request, that refusal itself is a compliance failure on the seller’s part — but for a business owner focused on their own deduction, a self-prepared, vendor-acknowledged purchase record still lets you substantiate the expense in the meantime.

Does this ₱500 threshold apply to VAT-registered sellers too? #

No. A VAT-registered seller must issue an invoice for every sale, regardless of the amount — the ₱500 threshold under Section 237 applies only to sellers who are not VAT-registered. Most individual wet market and palengke vendors are small enough to fall under the non-VAT threshold rules.

How often does the ₱500 threshold change? #

The Ease of Paying Taxes Act built in a periodic adjustment: the ₱500 amount is adjusted to its present value every three years, starting from the law’s effectivity on January 22, 2024, using the Consumer Price Index published by the Philippine Statistics Authority. A small business owner should recheck the current threshold every few years rather than assume ₱500 is permanent.

Summary #

A wet market vendor is often legally exempt from issuing an invoice under NIRC Section 237’s ₱500 threshold — but that exemption is about the seller’s obligation, not the buyer’s. A small business owner deducting the purchase still needs “other adequate records” under Section 34(A)(1)(b): a dated, itemized purchase log the vendor acknowledges, backed by a payment record where possible. Build that habit at the point of purchase rather than trying to reconstruct it at filing time.