State College Performing Governmental Functions Not Subject to Tax

July 11, 1969 BIR RULING NO. 010-69 West Visayas State College (Formerly Iloilo Normal School) Iloilo City Attention : Mr . Jose B . Ledesma President Gentlemen : This refers to your 1st Indorsement dated May 9, 1969 requesting information as to whether or not a state college is subject to the payment of documentary stamp tax as provided by Section 225 of the Tax Code. In reply, I have the honor to inform you that a state college (like the West Visayas State College) performing governmental functions is not subject to tax. Nevertheless, diplomas and transcript of records, although issued by a state college, are subject to the documentary stamp tax imposed by Section 225 of the Tax Code because they are not covered by the exceptions provided under Section 236 of the same Code. The tax, however, is charged to the students as recipients thereof, it being payable by either the party issuing or by the one accepting the certificates. LLphil Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue