BIR Ruling

July 14, 1976 Documentary & Science Stamp Taxes on Life Insurance Premium Policies of Nursing Graduates Undergoing Rural Health Program This refers to your letter dated July 12, 1976 requesting the opinion of this Office as to whether or not your Office is required to pay for the documentary stamps and science taxes on life insurance policies obtained by that Office on the lives of nursing graduates who participate in the Rural Health Practice Program of the Department of Health as a prerequisite to professional licensure. In reply, I have the honor to inform you that the documentary and science stamp taxes leviable on life insurance policies as prescribed by Section 220 of the Tax Code is the liability of the insurance company which issues such insurance policies. The fact that said tax may be shifted or passed to that Department, which pays the premiums on the policies thus obtained, will not constitute the tax as a tax on the Department of Health. Accordingly, although that Office is a government office, it cannot claim exemption from the payment of the documentary stamps and science taxes required to be affixed to the aforesaid life insurance policies.