Substituted Affixture and/or Adherence of Documentary Stamps

December 27, 1989 BIR RULING NO. 268-89 Rev. Reg. No. 5-88 000-00 268-89 Gentlemen : This refers to your letters dated May 11, June 1 and September 7, 1989 requesting for an authority to adhere documentary stamps to the cargo manifests instead of into each and every airwaybill. Your request was made allegedly to avoid tedious administrative effort in attaching documentary stamps to your voluminous airwaybills which necessarily entails great administrative work and which you cannot cope because of your lean work force. aisadc In reply, I regret to inform you that your request cannot be granted for lack of legal basis. Revenue Regulations No. 5-88 which amended Section 203 of Regulations No. 26 as amended by Regulations No. 77 and Revenue Regulations No. 3-75 enumerate the instances wherein a substituted affixture and/or adherence of documentary stamps may be authorized by the Commissioner of Internal Revenue. Since airwaybills are not among those enumerated, the present procedure regarding the affixture of documentary stamps shall be followed, i.e., by the purchase and affixture of documentary stamps of the proper value to the document or instrument sought to be taxed. Very truly yours, (SGD.) JOSE U. ONG Commissioner