Tax Liability of the Certificates of Stock issued to GSIS and SSS

October 28, 1959 BIR RULING NO. 532-59 The General Manager Reinsurance Company of the Orient, Inc. 208 Regina Building, Escolta M a n i l a S i r : This is in connection with your letter dated October 27, 1959 requesting a ruling on the question of whether or not the certificates of stock issued to the Government Service Insurance System and the Social Security System are subject to documentary stamp tax. The documentary stamp tax on original issue of certificates of stock is due from the company or corporation issuing certificates. The fact that the stockholders are exempt from tax does not avoid the imposition of the documentary stamp tax prescribed in section 212 of the National Internal Revenue code inasmuch as the exemption of the stockholders does not extend to the corporation. In view thereof, this Office is of the opinion that the certificates of stock issued to the Government Service Insurance System and the Social Security System are subject to the documentary stamp tax prescribed in section 212 of the Tax Code. cdll Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue