BIR Ruling

November 19, 1970 Aurora Investments, Inc. P.O. Box 4338 Manila Attention: Aurora P . Lebron President Gentlemen : This refers to your letter dated October 9, 1970 requesting information as to whether you are authorized to accept Certificates of Tax Exemption presented by your clients who are members of the diplomatic corps, issued by their Embassy with regard to the payment of documentary and science stamps required to be affixed on insurance policies. As represented by you, the Aurora Investments, Inc. serves as general agents for several non-life insurance companies and have for clients a number of individuals who are members of the diplomatic corps, and who are not invoking their tax exemption privilege with regard to the payment of documentary and science stamps which are required to be affixed on all insurance policies written in the Philippines; and that in support of their claim for exemption, you were presented with Certificates of Tax Exemption issued by their Embassy. In reply, I have the honor to inform you that you are not authorized to accept the aforesaid Certificates of Tax Exemption in lieu of the documentary and science stamps required to be affixed on their insurance policies for lack of legal basis. Documentary and science stamp taxes on insurance policies are imposed on and payable by the insurer if not paid by the insured. Besides, members of the diplomatic corps of foreign government are not exempt from the payment of the documentary and science stamps on their insurance policies written or issued here in the Philippines. (Sec. 236, Tax Code) cdti Very truly yours, CONRADO P. DIAZ Acting Commissioner of Internal Revenue