Request for Authority to Apply Tax Credit Certificates to Documentary Stamp Tax Liability

October 31, 1996 BIR RULING NO. 115-96 R.A. 226 000-00 115-96 Amerton Incorporated Ninoy Aquino Avenue, San Dionisio Paraaque, Metro Manila Attention: Ms . Renelia L . Yturzaeta Chief Finance Officer Gentlemen : This refers to your letter dated August 26, 1996 requesting, in effect, for authority to apply your tax credit certificates to your documentary stamp tax liability. It is represented that you are registered with the Board of Investments on a pioneer status under Certificate of Registration No. EP-88-830 engaged in the manufacture of electronic products; and that you are also a member of Semiconductor Electronics Industry Foundation, Inc. (SEIFI). cdt In reply, please be informed that pursuant to Article 21 of the Omnibus Investments Code (E.O. NO. 226), tax credit shall mean any of the credits against taxes and/or duties equal to those actually paid or would have been paid to evidence which a tax credit certificate shall be issued by . . . the Board, if so delegated by the Secretary of Finance. The tax credit certificates . . . issued by the Board . . . shall be used to pay taxes, duties, charges and fees due to the National Government . . . Such being the case, a Tax Credit Certificate duly issued by the Board of Investments (BOI) shall, upon proper application, be allowed to be used in payment of your documentary stamp tax liability. Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue