BIR Ruling

September 16, 1969 The New Zealand Insurance Company, Ltd. 9/F Vicente Madrigal Building 6793 Ayala Avenue, Makati Rizal Gentlemen : This refers to your letter dated July 28, 1969 requesting that you be authorized to affix the documentary and science stamps on your Premium Return (list of policies and endorsements issued by you) instead of affixing the stamps due on each and every copy of the policy and endorsement. cdpr Pursuant to Section 210 of the Tax Code, the documentary stamp must be affixed to the taxable documents at the time it is' issued or executed. Under Sections 220 and 221 of the same Code, as implemented by Section 63 of Regulations No. 26 otherwise known as the Revised Documentary Stamp Tax Regulations, the documentary stamp must be affixed to the first instruments by which the insurance is made or renewed. Until such time as the above-mentioned procedure is amended or modified, the same shall be followed. In view thereof, this Office regrets to inform you that your request has to be, as it is hereby, denied. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue