Certificates of Time Deposits Issued for the Account of the Bureau of Treasury are Subject to the Documentary Stamp Tax

August 6, 1991 BIR RULING NO. 146-91 180 2-86 146-91 Gentlemen : This refers to your letter dated March 4, 1991 requesting for a ruling as to whether or not certificates of time deposits issued by you for the account of the Bureau of Treasury are subject to documentary stamp tax considering that both entities are government corporations/agencies. It appears that you have been collecting documentary stamp tax on certificates of time deposits issued for the Bureau of Treasury but the latter maintains the view that their certificates of time deposits are exempt from documentary stamp tax. In reply, please be informed that effective June 11, 1984 and March 10, 1987, respectively, under P.D. No. 1931 and E.O. No. 93, the tax exemption and/or preferential tax treatment in favor of government-owned or controlled corporations, including their subsidiaries and all other units of government had been withdrawn. (RMC No. 1-85) Such being the case, the certificates of time deposits issued by you for the account of the Bureau of Treasury are subject to the documentary stamp tax imposed under Section 180 of the Tax Code, as amended. cdtech Very truly yours, (SGD.) JOSE U. ONG Commissioner