BIR Ruling [UN-158-94]

May 24, 1994 BIR RULING [UN-158-94] White House Development Corp. 10th Floor, Metrobank Plaza Bldg. Sen. Gil Puyat Ave. Makati, Metro Manila Attention: Mr . Misael P . Soliman Treasury Gentlemen : This refers to your letter dated 16 May 1994 stating that you are a real estate company engaged in low-cost and socialized housing projects located in Cavite, Rizal, Laguna and possibly other localities; that in order to facilitate efficient and smooth operation in volume, you would like to use/purchase a metering machine; and that you shall be procuring metered documentary stamps from the BIR Makati Office and affix the same on documents affecting various localities. In connection therewith, you now request for approval/authorization to use the metered documentary stamps purchased from the BIR Makati Office (where your document processing is located/centralized) in documents of various projects located in Cavite, Laguna, Rizal and possibly other localities. In reply thereto, please be informed that the stamp tax on instrument of sale or conveyance of real property shall be paid through the Revenue District Office having jurisdiction over the locality where the real property sold/disposed is located (par. 3(2.1), RMC 44-86) Moreover, payment of the documentary stamp tax is effected by the purchase, affixture and subsequent cancellation of documentary stamps (or notation of payment of documentary stamp tax with denomination of P10.00 or more) on the documents at the time such act is done or transaction had, meaning on the date of execution or signing of the document by the parties thereto, and not at the time of its notarization (RMC 57-91). Furthermore, since, as represented, the real properties of White House Development Corp. to be transferred to the vendees are located in Cavite, Rizal, Laguna and possibly other localities in the Philippines, that it would be very difficult not to say physically impossible to effect purchase of DST through the various RDO's where the real properties are located, your request to use the metered documentary stamps purchased from the BIR Makati Office in documents of various projects in different localities is hereby granted, (BIR Ruling No. 004-92 dated January 7, 1992) cdta Very truly yours, ALICIA P. CLEMENO Acting Assistant Commissioner Legal Service