BIR Ruling

June 19, 1969 Bulacan College of Arts and Trades Malolos, Bulacan Attention: Mr . Leandro P . Jimenez Principal Gentlemen : This refers to your letter dated May 21, 1969 requesting information as to whether or not the diplomas and transcript of records issued by the Bulacan College of Arts and Trades which is a government institution, are subject to documentary and science stamps. In reply, I have the honor to inform you that diplomas and transcript of records issued by the aforesaid college are subject to the documentary and science stamp taxes because they are not covered by the exceptions provided under Section 236 of the Tax Code or of Section 4 of Republic Act No. 5448. The Bulacan College of Arts and Trades being a governmental institution, cannot be subject to tax. The Tax, however, can be charged to the students as recipients thereof, it being payable by either the party issuing or by the one accepting the certificates in accordance with Section 210 of the Tax Code. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue