BIR Ruling

September 25, 1968 The Philippines Veterans Bank Manila Attention: Mr . Ricardo D . Galano Secretary to the Board Gentlemen : This refers to your letter dated May 28, 1968 requesting for a ruling on whether or not the Philippine Veterans Bank is liable to the payment of documentary stamp tax under Section 212 of the National Internal Revenue Code, on the original issue of stock certificates to the veterans of World War II. In reply, I have the honor to inform you that this Office made a careful study of Republic Act No. 3518, charter of the Philippines Veterans Bank, and that the law does not contain any provision exempting the bank from the aforesaid tax liability. It is a cardinal rule in taxation that there is no presumption, in fact or in law, exempting a person, natural or juridical, from taxation. A law must exist precisely for that purpose, and the evidence upon which it is based must be convincing and clear. In view thereof, the Philippines Veterans Bank is liable to the payment of documentary stamp tax on the original issue of stock certificates to the veterans. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue