BIR Ruling

October 2, 1970 Sikatuna Transfer, Inc. 305 Jalandoni Building 1444 A. Mabini St. Ermita, Manila Attention: Mr . Irineo Obedencia Assistant Manager Gentlemen : This refers to your letter dated August 26, 1970 stating that the purposes for which that corporation is formed are: "a. To provide corporate organizations for whom it may act as Registry and/or Transfer Agent with the facilities for registration., transfer or exchange of their securities; b. To provide the same with facilities for the preparation, recording, keeping and conservation of all evidences of ownership or indebtedness; c. To do each and every act necessary, suitable or proper for the accomplishment of any of the purposes or the attainment of any one or more of the objects herein enumerated or which at any time appears conducive to or expedient for the protection or benefit of this corporation." For your guidance and that of you clients, you now request for information on the following: "1. Under what schedule of tax our company falls? "2. Is there any other tax liability after the payment of privilege tax of P50.00? "3. How much documentary stamp tax to be affixed on original issue of stock? "4. How much documentary stamp tax to be affixed on reissue of cancelled stock certificate? "5. Are Science Taxes still to be affixed thereon in items 1 and 2?" In reply, I have the honor to inform you that for internal revenue purposes, your corporation is an independent contractor subject to the annual fixed tax of P50.00, pursuant to Section 182(A) (1) of the Tax Code. Aside from the fixed tax, you are also subject to the 3% tax on your gross receipts, pursuant to Section 191(18) of the same Code. aisadc As to the documentary stamp tax to be affixed on original issue of certificates of stock, Section 212 of the Tax Code, as amended, imposes a documentary stamp tax of fifty centavos on each two hundred pesos or fractional part thereof, of the par value of such certificates; provided, that in the case of the original issue of stock without par value the amount of the documentary stamp tax shall be based upon the actual consideration received by the corporation for the issuance of such stock, and in the case of stock dividends, on he actual value represented by each share. The same amount of documentary stamp tax is imposed on re-issue of cancelled stock certificates because in such case, there is an original issue of a certificate of stock. Science stamp tax is likewise imposed on the said stock certificates in an amount equivalent to the documentary stamp tax pursuant to Republic Act No. 5448. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue