BIR Ruling No. 543-2017

REPUBLIC OF THE FHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Sec. 173& {84 NIRC: P.D. 000-00 1-22-7 3l-3-30 17 Person to Contact: Chief, Law & Legislative Division Tel Nos. 926-55-36/927-09-63

National Food Authority Quezon Provinciai Office Brgy. Isabang, Lucena City

Attention: Engr. Alwin M. Uv Provincial Manager

Gentlemen:

Provincial Office is exempt fron the payment of documentary stamp tax (DST) on insurance policies. Authority (NFA) - Quezon Provincial Office, for confirmation that the NFA - Quezon This refers to your letter dated May 30, 2017 requesting on behalf of the National Food

DST on all policics of insurance upon property. Also, Section 184 of the same Code holds that the insurance policy and the premium charged on the estimated insurance coverage. as it is reflected on the face of the policy, and which shall be the amount on which the DST due shall that there shall be levied, collected and paid upon documents. instruments and papers DST shall be based on the amount of premium charged. DST shall be due upon the issuance of be based. evidencing the act done or transaction had or the agreement or contract has been perfected. In rcply. please be informed that Section 173 of the Tax Code, as amended. provides

documents. instruments and papers for the national government, made at the instance and for the sole use of some other branch of the national government, are exempted from documentary (now the NFA) stated under Presidential Decree (P.D.) No. 4. as amended by P.D. Nos. 699 Regulations (RR) No. 13-04 dated December 23, 2004 provides that certificates placed upon stamp tax. viz: and 1485. However, Section 199 of the Tax Code, as amended, and as implemented by Revenue Executive Order No. 93 withdrew the tax privileges of the National Grains Authority

provisions of Section 173 notwithstanding. the.following instruments. documents. and papers shall be exempt from the documentary stump tax: "Sec. 199. Documents and Papers not Subject to Stamp Tax --- The

u) Policies of insurance or annuities .

b) Certificates of oath administered to any government official in his official capacity or of acknowledgement by any government official in

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National Food Authority Page 2 of 2

the performance of his official duties: written appearance in any court by any government official. in his official capacity: certificates of the

paper required to he filed in court hy any person or party thereto. administration of oaths to any person as to the authenticity of any governments: affidavits of poor persons for the purpose of proving filed in couris by or for the national, provincial. city. or municipul poverty; statements and other compulsory information required of whether the proceedings be civil or criminal: papers and documents

persons or corporations by the rules and regulations of the national. provincial. city, or municipal governments exclusively for statistical purposes and which are wholly for the use of the bureau or office in which they are filed, and not at the instance or for the use or benefi. of the person filing them: certified copies and other.certificates placed upon documents..instruments, and papers for the national, provincial. city. or municipal governments, made at the instance and for the sole use of some other branch of the national, provincial, city or municipal governments; . . .

to the NFA - Quezon Provincial Office, being certificates for a government-owned and In view of the foregoing, the certificates of insurance policy that will be issued by GSIS

controlled corporation under the Office of the President, made at its instance and for its sole

(DST). use, and for the account of the Bureau of Treasury are exempt from the documentary stamp tax

if upon investigation, it will be disclosed that the facts are different. then this ruling shall be considered null and void. This ruling is being issued on the basis of the foregoing facts as represented. However.

Very truly yours.

AaanM

K-1-MCuS Commissioner of Internal Revenue CAESAR R. DULAY 011347