Documentary Stamp Tax Exemption of the Certificates of Stocks Issued by Feati Industries, Inc.

August 11, 1958 BIR RULING NO. 431-58 Feati Industries, Inc. c/o Feati Tech Bldg. Sta. Cruz, Manila Gentlemen : In reply to your letter dated July 5, 1958, requesting the opinion of this Office as to whether or not you are exempt from paying the documentary stamp tax on certificates of stocks issued by you, in view of the tax exemption granted in your favor, under the provisions of Republic Act 901, I have the honor to inform you that the exemption granted under the provisions of Republic Act 901 covers only taxes directly payable by the new and necessary industry in respect to said industry. According to the certificate of tax exemption, a photostatic copy of which is attached to you letter, the tax exemption granted in your favor is in respect to the manufacture of electric power distribution transformers, small fan and blower motors, single face induction motors, three-phase induction motors, and alternating current generators. If your corporation is engaged exclusively in the production of articles covered by its tax-exemption certificate and that it is not engaged in any taxable activity, the certificate of stocks issued by it are exempt from the documentary stamp tax prescribed in Section 212 of the National Internal Revenue Code; otherwise; they are subject thereto. Very truly yours, (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue