BIR Ruling No. 055-82

March 4, 1982 BIR RULING NO. 055-82 228-00 32-81 055-82 Central Bank of the Philippines SPP-MGR-CGS Complex West Avenue, Diliman Quezon City Attention: Mr . Cesar J . Lomotan Superintendent Gentlemen : In reply to your letter dated March 9, 1981, I have the honor to inform you that although under Section 16 of Republic Act No. 1161, as amended, the Social Security System is exempt from the documentary stamp tax on documents required in connection with its operations, said exemption has been superseded by Section 23 of P.D. No. 1177, effective on July 30, 1977 which requires government-owned or controlled corporations to pay income taxes, customs duties and other taxes and fees as are imposed under revenue laws. (BIR Ruling No. 32-81 dated February 4, 1981). Accordingly, and in line with BIR Ruling No. 127-79 dated December 13, 1979, the printed 1980 MICR encoded checks of the Social Security System delivered by the Security Printing Plant are subject to the payment of documentary stamp tax. However, SSS shall not be required to pay cash or its equivalent for the taxes due from it, but instead the revenue collecting agencies shall issue a "payment compliance certificate" indicating the nature of the assessment and amount due. The subsidy shall be effected through journal vouchers or their equivalent. (Section 6, Finance Circular No. 2-78, dated May 6, 1978) Very truly yours, RUBEN B. ANCHETA Acting Commissioner