BIR Ruling No. 101-83

June 13, 1983 BIR RULING NO. 101-83 Gentlemen : This refers to your 1st Indorsement dated March 28, 1983 requesting confirmation regarding the claim of the Government Service Insurance System that it is exempt from the payment of the documentary stamp tax on its MICR checks. In reply, please be informed that based on Opinion No. 126, S. 1981 dated September 8, 1981 of the Minister of Justice, this Office has ruled that although Section 23 of Presidential Decree No. 1177 subjects all units of government, including government owned and controlled corporation to pay income taxes, customs duties and other taxes and fees as are imposed under revenue laws, said provision of the law has not revoked or modified the tax exemption granted under the GSIS Charter. Under Section 33 of Presidential Decree No. 1146 amending Commonwealth Act No. 186, otherwise known as the GSIS Charter, the exemption from taxes, assessments, fees and charges or duties granted thereunder to the GSIS shall continue unless specifically and expressly revoked. (BIR Ruling No. 280-82 dated November 10, 1982). aisadc In view thereof, the MICR checks in question of the Government Service Insurance System are exempt from the payment of documentary stamp tax. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue