Affixture of Documentary Stamps on Its Business (Premium) Register

February 19, 1987 BIR RULING NO. 052-87 213 (249) 209-86 052-87 Gentlemen : This refers to your letters dated January 21 and June 30, 1986 requesting that your client, Lincoln Philippine Life Insurance Co., Inc. be allowed to affix documentary stamps on its Business (Premium) Register on a daily basis instead of on individual life insurance policies. It is represented that the First Year Business Register of Lincoln Philippine Life Insurance Co. Inc. (LPL) is similar to a Premium Register as it contains a list of all policies issued and all other data necessary to determine the correct documentary stamp tax due; that its use by LPL is intended to enhance effective tax compliance and control; and that such a set-up would be more convenient on the part of the Bureau inasmuch as it facilitates the examination of LPL's documentary stamp tax liability. adc In reply, please be informed that pursuant to Revenue Regulations No. 3-75 amending Section 203 of Revenue Regulations No. 26 (Documentary Stamp Tax Regulations) and implementing Section 213 (formerly Section 249) of the Tax Code, pertinent portion of which is quoted hereunder as follows: " . . . In meritorious cases . . . the Commissioner of Internal Revenue, may in his discretion, authorize . . . that with respect to insurance policies the documentary stamps shall be adhered to the register copy or premium register; . . . " your request is hereby granted subject to the following conditions: 1. The LPL will purchase in advance documentary stamps or make advance payments for their documentary stamp tax requirements to the end that they shall see to it that the available documentary stamps (or advance payment thereof) to cover future affixtures shall at least be the P10,000.00 mark and accordingly they will immediately make replenishments; 2. The computerized forms to be used for the Business (Premium) Register shall be pre-numbered and shall first be registered with the B.I.R. as loose leaf black sheet or plain paper with serial numbers. Damaged or cancelled or unused sheets with their serial numbers shall still form part of the records or the premium register; and 3. The affixtures of documentary stamps and/or equivalent payment of the documentary stamp tax shall be reflected in the premium registers on a daily basis and it shall be sufficient for an annotation on the face of the policies issued that "Documentary stamps to the value of P______ have been affixed to the Business (Premium) Register." Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner