BIR Ruling
BIR Ruling • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • Sep 7, 1971
Full text
September 7, 1971 Messrs. Antonio C. Pacis & Efrenilo M. Cayanga 34d Floor, Comtrust Building Ayala Avenue, Makati, Rizal Attention: Mr . Raul de Leon S i r : In reply to your letter dated July 8, 1971, requesting opinion whether or not the initial transfer of stock certificates from the individual's name to his investment account number with the investment manager or vice-versa is subject to documentary and science stamp taxes, I have the honor to inform you that based on the foregoing facts, inasmuch as there is no transfer or change in the legal ownership of said stock certificate and the beneficial title remains with the owner and the income earned under said account is included in the individual's tax return, such transfer is not subject to documentary and science stamp taxes. In other words, the transfer of stock certificates from the individual's name to his investment account number without any change in par or face value is exempt from tax. (Sections 13 and 15, Regulations No. 26, Department of Finance;. Sec. 212, Tax Code) Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue
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