Use of Delivery Receipts as Way Bill for Goods Transported

February 16, 1959 BIR RULING NO. 082-59 Allied Brokerage Corporation Robert Dollar Bldg., Port Area Manila Gentlemen : In reply to your letter dated February 9, 1959, I have the honor to inform you that this Office has no objection to your use of delivery receipts as way bill for goods transported by you. However, the said delivery receipts are subject to the documentary stamp tax prescribed in Section 227 of the National Internal Revenue Code, pursuant to Section 122 of Regulations No. 26 of the Department of Finance which reads as follows: "SEC. 122. Receipts of delivery of goods . Receipts given by a company to a shipper which serve as memorandum for delivery of goods to the express company, should be stamped in accordance with paragraph (a) of Section 1449 of the Administrative Code. (now Section 227 of the National Internal Revenue Code) The law requires that for each shipment received for carriage or transportation, the common carrier shall issue to the shipper or consignor a stamped bill of lading, manifest, or other evidence of receipt and forwarding." In accordance with the abovequoted provisions, of Regulations No. 26, documentary stamp tax is due on each delivery receipt, said tax to be based on the total value of the goods delivered by each truck. The stamps should be affixed to the delivery receipt or to the duplicate thereof if duplicate is kept by the transportation company. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue