BIR Ruling [DA-600-06]

October 10, 2006 BIR RULING [DA-600-06] Section 101 (A) (2); DA-618-2004 Mr. Elias Jesus F. Santos Head-Land Titling Office 11th Floor, Quezon City Hall Quezon City S i r : This refers to your letter dated September 6, 2006 requesting for exemption from the payment of donor's tax relative to the donation of real property by Mr. Bonifacio C. Regalado in favor of The City Government of Quezon City. Documents show that on July 26, 1978, a Deed of Donation was executed by and between Bonifacio C. Regalado, and The City Government of Quezon City, as represented by then Hon. Adelina S. Rodriguez, transferring to The City Government of Quezon City two (2) parcels of land with a total area of 14,265 square meters situated in Quezon City and covered by Transfer Certificate of Title Nos. RT-127122(172924)PR-46413 and RT-127121(172873)PR-46412 respectively; and that The City Government of Quezon City is a public corporation. In reply, please be informed that since the donee is a political subdivision of the Government, the aforementioned donation of two (2) parcels of land is exempt from the payment of donor's tax pursuant to Section 101 (A)(2) of the Tax Code of 1997, as amended. DCScaT Moreover, the aforesaid Deed of Donation is not subject to the documentary stamp tax under Section 196 of the Tax Code of 1997, as amended, but only to the documentary stamp tax of P15.00 on certification under Section 188 of the same Code. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered as null and void. Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service