Issuance of New Stock Certificates - No Documentary Stamp Tax

March 10, 1993 BIR RULING NO. 093-93 ISSUANCE OF NEW STOCK CERTIFICATES NO DOCUMENTARY STAMP TAX 175 000-00 093-93 Sumulong, Sumulong, Paras & Abaa 8th Floor, Sagittarius Bldg. H.V. de la Costa St., Salcedo Village Makati, Metro Manila Attention: Atty . Severino P . R . Sumulong This refers to your letter dated January 20, 1993 stating that Zeller Plastik (S.E. Asia) PH, Inc. recently changed its name to Zeller Plastik Philippines, Inc.; that Stockholder X currently has three (3) stock certificates with one (1) million shares each; and that he would like to consolidate all the three (3) stock certificates into only one which will reflect the aggregate sum of three (3) million shares and the new corporate name. Based on the foregoing, you are requesting opinion as to whether Stockholder X is still liable to pay documentary stamp tax on the issuance of a new stock certificate. In reply, please be informed that the issuance of a new stock certificate which will consolidate all the three (3) stock certificates into only one reflecting the aggregate sum of three (3) million shares and the new corporate name is not subject to the documentary stamp tax imposed by Section 175 of the Tax Code, provided the new certificate is issued to the same stockholder (Stockholder X) and its par value is not higher than the three (3) replaced stock certificates. JOSE U. ONG Commissioner of Internal Revenue