BIR Ruling

May 21, 1969 The Director Bureau of Private Schools Manila S i r : This refers to your letter dated March 5, 1969 requesting information as to whether or not certificates of graduation or diplomas issued by private schools to graduating students are subject to the documentary and science stamp taxes. In reply, I have the honor to inform you that such documents are subject to the documentary stamp tax pursuant to Section 225 of the Tax Code, which imposes a documentary stamp tax of thirty centavos on such certificate of any description required by law, or by rules or regulations of a public office, or which is issued for the purpose of giving information, or establishing proof of a fact, and not otherwise specified therein. Section 76 of the Regulations No. 26 otherwise known as the Revised Documentary Stamp Tax Regulations, which implements Section 225 of the Tax Code provides that certificates issued by a public official or person acting in a public capacity are subject to the documentary stamp tax. Inasmuch as school authorities of private schools duly recognized by the Government are considered persons acting in a public capacity, the certificates of graduation or diplomas issued by them to graduating students are subject to the documentary as well as the science stamp taxes. cdtech Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue