Commercial Papers Subject to 35% Transaction Tax Not Limited to those Issued by Corporations Only
BIR Ruling No. 095-80 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jul 7, 1980
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July 7, 1980 BIR RULING NO. 095-80 Messrs. Bito, Misa & Lozada Ramon Magsaysay Center Roxas Blvd., Manila Gentlemen : In reply to your letter dated May 26, 1980, I have the honor to inform you that under Section 210(b) of the Tax Code of 1977, as amended, the 35% transaction tax is imposed on every commercial paper issued in the primary market as principal instrument. A "commercial paper" is therein defined as "an instrument evidencing indebtedness of any person or entity, including banks and non-banks performing quasi-banking functions, which is issued, endorsed, sold, transferred or in any manner conveyed to another person or entity, either with or without recourse and irrespective of maturity." In other words, commercial papers subject to the 35% transaction tax are not limited to those issued by corporations only. Commercial papers falling within the definition which are subject to the said tax include those issued by individuals, partnerships and other entities including corporations. Very truly yours, RUBEN B. ANCHETA Acting Commissioner
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