Exemption of a Ship Mortgage from the DST
BIR Ruling No. 143-89 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jul 12, 1989
Full text
July 12, 1989 BIR RULING NO. 143-89 195 068-83 143-89 Gentlemen : This refers to your letter dated June 5, 1989 requesting in behalf of your client, Kredietbank International (Pacific) Limited, for a ruling exempting from the documentary stamp tax the ship mortgage executed abroad by Kennewick Ltd. in favor of your client. It is represented that Kennewick Ltd. is a non-resident foreign corporation not doing business in the Philippines and organized and existing under the laws of Liberia while Kredietbank International (Pacific) Limited is also a non-resident foreign corporation incorporated in the Republic of Vanuatu; that the former is the owner of the vessel, M/V "Pacific Golfer"; and that to secure a loan, it executed a First Preferred Liberian Mortgage (copy attached) on the said vessel in favor of your client. acd In reply, please be informed that the aforesaid First Preferred Liberian Mortgage, being executed in HongKong, is not subject to the documentary stamp tax imposed by Section 195 of the Tax Code. This is in consonance with the rulings previously issued by this Office to the effect that the documentary stamp tax, being an excise tax, is applicable only to transactions effected and consummated within the Philippines. Very truly yours, (SGD.) JOSE U. ONG Commissioner
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