Service Contractors under Presidential Decree No. 87 Exempt from Payment of Documentary Stamp Tax on Voucher Checks

July 10, 1981 BIR RULING NO. 106-81 222-00 140-79 106-81 Messrs. Sycip, Salazar, Feliciano and Hernandez PAIC Bldg. 105 Paseo de Roxas Makati, Metro Manila Attention: Mr . Jose L . Escabido Gentlemen : This refers to your letter dated May 20, 1981, requesting on behalf of your clients, PHILIPS PETROLEUM CO., PHILS., PHILIPS PETROLEUM INTERNATIONAL CORP., Cebu, and PHILIPS INTERNATIONAL CORPORATION, Philippines, exemption from the payment of documentary stamps taxes on voucher checks to be printed for them by the Security Printing Plant of the Central Bank of the Philippines, pursuant to Paragraph (a) Section 12 of P.D. No. 87, known as the "Oil Exploration Act", which provides as follows: "Sec. 12. Privilege of Contractor . The provisions of any law to the contrary notwithstanding, a contract executed under this Act may provide that the contractor shall have the following privileges: a) Exemption from all taxes except income tax. xxx xxx xxx It appears that, as service contractors under P.D. No. 87; each of your clients has a contract with the Security Printing Plant of the Central Bank of the Philippines under which the latter is to print voucher checks for the former; that under the service contracts entered into by said service contractors with the Bureau of Energy Development, Ministry of Energy, the exemption provision of the aforesaid decree is also expressly embodied. cdt In reply, I have the honor to inform you that as service contractors under Presidential Decree No. 87, your clients are exempt from all taxes, except income tax. Accordingly, they are exempt from the payment of the documentary stamp tax on all their voucher checks printed by the Security Printing Plant of the Central Bank of the Philippines. (BIR Ruling No. 228-00-000-62-71-81). Very truly yours, RUBEN B. ANCHETA Acting Commissioner