BIR Ruling

March 20, 1968 Mariwasa Distributors, Inc. 767 Aurora Boulevard Quezon City Attention: Alberto S . Ortiz Asst . Corporate Secretary Gentlemen : This has reference to your letter dated March 6, 1968 requesting information as to how much documentary stamp should be used where a corporation has changed the par value of its share form P100.00 to P10.00 per share, and wishes to retire the old issued certificates in exchange for new stock certificates. In reply, I have the honor to inform you that no documentary stamp tax is due upon certificates of stock issued to replace prior or original certificates, provided the new certificates are issued to the same person and the tax has been paid on the original issue, inasmuch as the issuance of these new certificates is not an original issue either on organization or reorganization. (Secs. 13, Reg. No. 26, Department of Finance). If documentary stamps were affixed to the original certificates of stock, no documentary stamps need be affixed to the certificates of stock issued to replace the old certificate provided that the new certificates carry a notation which certifies in effect the amount of documentary stamps affixed to the old certificates. (Ruling, BIR dated Jan. 3, 1955). cdta Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue