Addenda to the Chattel Mortgage by and between Marubeni Corp. and Maricalum Mining Corp. are Not Subject to Documentary Stamp Tax
BIR Ruling No. 059-91 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Apr 5, 1991
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April 5, 1991 BIR RULING NO. 059-91 195 218-90 059-91 Gentlemen : In reply to your letter dated January 22, 1991, I have the honor to inform you that considering that under BIR Ruling No. 195-000-00-218-90 dated November 22, 1990, no documentary stamp tax is due on the seven addenda to the Chattel Mortgage executed on May 31, 1985 by and between Marubeni Corporation (the mortgagee) and Maricalum Mining Corporation (the mortgagor) there being no additional amount loaned but only an additional collateral as security to the original loan, the Eighth Addendum as well as those addenda which the parties may execute in the future by virtue of the after acquired property provision in the Chattel Mortgage Contract are likewise not subject to the documentary stamp tax as long as there is no change in the amount of the original loan and the addenda being merely additional security thereof. Very truly yours, (SGD.) JOSE U. ONG Commissioner
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