Affixing of a Separate Set of Documentary Stamps

February 10, 1958 BIR RULING NO. 107-58 The Philippine National Bank Manila Attention : Mr . Ramon B . De Los Reyes Chief , Legal Department Gentlemen : This is with reference to your request for a ruling on whether or not it is necessary to affix a separate set of documentary stamps on each of the two drafts issued under the following circumstances: cdta "Letters of credit opened by Japanese banks require of each beneficiary to draw on one of the following: "(a) the Japanese buyer (b) the opening bank for account of the Japanese buyer (c) the Manila correspondent of the opening bank, and (d) the New York branch or correspondent of the opening bank "Drawing on (a), (b) or (c) in turn requires of the negotiating bank to draw another draft on the New York branch or correspondent of the opening bank in reimbursement and as a result, two separate drafts are drawn under the same transaction." As described above, the first draft which was delivered to the negotiating bank was not sent abroad, but instead, another draft made by the bank was sent to the New York branch or corresponding of the opening bank. The first draft serves as authority for the bank to issue the second draft. As each of said draft serves a definite stamp tax prescribed in Section 219 of the National Internal Revenue Code. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue