BIR Ruling

July 7, 1972 Action Line c/o The Manila Times P. O. Box 775, Manila Gentlemen : This refers to the letter dated February 14, 1972 of Mr. Niceforo N. Benitez, PNB Branch, Tacloban City, asking a ruling as to whether a certification as to the amount of tuition fees paid during the year, issued by the Cashier of the high school department, Divine Word University is subject to documentary and science stamp taxes. As represented, the cashier is charging the amount of P1.00 plus P0.60 for the cost of documentary and science stamps which are to be affixed to the certifications to be issued. cdt In reply thereto, I have the honor to inform you that the word "Certificate" is defined in Revenue Regulations No. 26 of the Department of Finance as follows: "SEC. 75. A certificate is a statement in writing by a person having a public or official status concerning some matter within his knowledge or authority ; a writing by which testimony is given that a fact has or has not taken place ." (Emphasis supplied). It appearing that the certification of the Cashier is considered a certificate issued for the purpose of establishing proof of a fact, the same is subject to the documentary stamp tax of P0.30 provided for under Section 225 of the Tax Code, and to another P0.30 Science stamp tax, pursuant to Section 4, Republic Act No. 5448. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue