Correct Amount of Documentary Stamp Tax on a Deed of Assignment of Letter of Credit

February 8, 1994 BIR RULING NO. 051-94 182; 198 000-00 051-94 Eastland Jenny's Avenue, Bo. Rosario Pasig, Metro Manila Attention: Ms . Eden K . See Asst . Accounting Manager Gentlemen : This refers to your letter dated September 23, 1993, requesting information on the correct amount of documentary stamp tax on a Deed of Assignment of Letter of Credit, specimen of which is attached thereto. In reply, please be informed that pursuant to Section 182 of the Tax Code, letters of credit drawn in but payable out of the Philippines are subject to documentary stamp tax at the rate of P0.30 on each P200.00 or fractional part thereof of the face value of such letters of credit, or the Philippine equivalent of such face value, if expressed in foreign currency. Such being the case, the assignment of such letters of credit is subject to the same rate of tax pursuant to Section 198 of the same Code. Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue