Whether the United Cooperative NGO, a Non-Stock Corporation Registered with the Securities and Exchange Commission (SEC) Can Use the Official Receipts of Another Duly Registered Multi-Purpose Cooperative for Purposes of Investment

April 3, 1995 BIR RULING NO. 064-95 239 000-00 064-95 Ms. Belen B. Calixto 109 Malumanay Street Teachers Village Quezon City M a d a m : This refers to your letter dated March 14, 1995 requesting, in effect, for a ruling as to whether or not the United Cooperative NGO, a non-stock corporation registered with the Securities and Exchange Commission (SEC) can use the official receipts of another duly registered multi-purpose cooperative for purposes of investment. In reply, please be informed that Section 239 of the Tax Code, as amended, provides, viz: "SEC. 239. Printing of Receipts or Sales or Commercial Invoices . All persons who print receipts or sales or commercial invoices shall, for every job order, secure from the Bureau of Internal Revenue an authority to print said receipts or invoices before printing the same. "No authority to print receipts or sales or commercial invoices shall be granted unless the receipts or invoices to be printed are serially numbered and shall show, among other things, the name, business, style, taxpayer identification number and business address of the person or entity to use the same. "Within twenty (20) days from the end of every calendar quarter, the printer shall submit to the Bureau of Internal Revenue a report containing the following information; "(1) Names, addresses, taxpayer identification number of the persons or entities for who the receipts or sales or commercial invoices were printed during the preceding quarter and "(2) Quantity of receipts of invoices printed and the serial number of the receipts or invoices in each booklet." llcd Such being the case, and since the United Cooperative NGO and the other multi-purpose cooperative being referred to in your letter are juridical entities having a separate and distinct personalities, this Office is of the opinion as it hereby holds that the United Cooperative NGO cannot use for investment purposes or for any other purpose the official receipts of the other multi-purpose cooperative you are referring to in your letter since it would violate the above-quoted provisions of Section 239 of the Tax Code, as amended. Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue