BIR Ruling No. 109-82
BIR Ruling No. 109-82 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Apr 6, 1982
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April 6, 1982 BIR RULING NO. 109-82 245-00 000-00 109-82 Atty. Ramon D. Pagarigan Acting Second Deputy Registry of Deeds of Metropolitan Manila, District I M a n i l a S i r : This refers to your letter dated June 11, 1980 to the Minister of Finance, requesting a ruling on the amount of documentary stamps tax due on a Deed whereby a parcel of real property is exchanged for subscribed shares of stock in a corporation. In reply thereto, I have the honor to inform you that a conveyance or deed whereby land is assigned or transferred to the purchaser is subject to documentary stamp tax based on the consideration or value received or contracted to be paid for such realty. (Sec. 245, Tax Code) A stock in a corporation is a valuable consideration for transfer of real properties. (Section 177, Documentary Stamp Tax Regulations) Accordingly, if a parcel of real property is exchanged with stocks in a corporation, the latter is the consideration, the value of which shall be the basis of the documentary stamp tax due on the aforesaid Deed. cdti Very truly yours, RUBEN B. ANCHETA Acting Commissioner
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