BIR Ruling

May 29, 1967 The President Bankers Association of the Philippines Manila, Philippines S i r : This has reference to your request that the ruling of this Office, holding that letters of credit are subject to the documentary stamp tax imposed by Section 219 of the Tax Code, be given a prospective effect. In reply, I regret to inform you that your request cannot be granted for lack of legal basis. The ruling in question being but a mere statement of the provisions of Section 210, 218 and 219 of the Tax Code, this Office has no basis whatever for postponing the effectivity thereof. For to do so would, in effect, be postponing the effectivity of the law which this Office cannot do. It is only the legislative body that can postpone the effectivity of the law thru proper amendment thereof. LibLex Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue