Affixation of the Documentary Stamps on the First Premium Receipts Duplicate

September 10, 1958 BIR RULING NO. 511-58 Great Pacific Life Assurance Corporation 484 Rosario St., Binondo Manila Gentlemen : This is in connection with your letter dated August 1, 1958, requesting that you be allowed to affix the documentary stamps on the duplicate kept by you of the first premium receipts issued by your corporation. llcd Section 203 of Revenue Regulations No. 26 as amended by Regulations No. 77 provides as follows: "Sec. 203. Manner of payment of documentary stamp tax . The payment of the documentary stamp tax . . . shall be made by the purchase and affixture of documentary stamps of the proper value to the document or instrument sought to be taxed or to any other paper which the law indicates as the proper recipient of the stamp: Provided, That in cases of warehouse receipts, certificates of stock, passage tickets, and other documents having stubs or duplicates kept by the persons issuing them, the documentary stamps shall be adhered to the stubs or to the duplicates thereof, and that a note properly initialed by a responsible person on the face of such documents shall be made as follows: 'Documentary stamps to the value of P____ have been affixed to the stub, or to the duplicate (as the case may be):' . . ." The abovequoted provision of Regulations 26 of the Department of Finance requires that the stamps shall be affixed to the taxable document itself, except in cases of documents having stubs or duplicate kept by the person issuing the same, in which case the stamps shall be affixed to the stubs or duplicate thereof. In the case of life insurance policies, the taxable document is the policy itself. The stamps should, therefore, be affixed thereto and not on the duplicate of the first premium receipt . However, if you retain a duplicate copy of each policy issued by you, the stamps should be affixed to such duplicate copy of the policy pursuant to the abovequoted provision of Regulations No. 26 of the Department of Finance. LibLex Very truly yours, (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue