Revised Documentary Stamp Tax Regulations

March 26, 1924 REVENUE REGULATIONS NO. 026-24 REVISED DOCUMENTARY STAMP TAX REGULATIONS 1 SECTION 1. Scope . Under the provisions of sections 1449-1452 and 2721 of the Administrative Code, and in connection with the provisions of section 79 (B) of Act No. 2803, the following regulations relative to documents and papers subject to and exempt from the stamp tax, the manner in which the documentary stamp tax shall be collected and paid, and the procedure to be followed by the provincial and deputy treasurers and by persons subject to the payment of the said tax, shall supersede all precedents, rulings and regulations heretofore published on the same subject and shall be known as Regulations No. 26, or "The Revised Documentary Stamp Tax Regulations." aETADI SECTION 2. Persons Liable. Upon documents, instruments, and papers, and upon acceptances, assignments, sales, and transfers of the obligation, right, or property incident thereto documentary taxes for and in respect of the transaction so had or accomplished shall be paid as hereinafter prescribed, by the person making, signing, issuing, accepting, or transferring the same, and at the time such act is done or transaction had. SECTION 3. Duplicates of Documents Which are Subject to Tax . The duplicate of a document would only be subject to the stamp tax where the same has been substituted and used in place of the original, and the original itself can not be reached by taxation. BONDS, DEBENTURES, AND CERTIFICATES OF INDEBTEDNESS On all bonds, debentures, and certificates of indebtedness issued by any association, company or corporation, on each two hundred pesos or fractional part thereof, of the face value of such documents, twenty centavos. (Section 1449 ( a ), Act No. 2711.) ( See also Sec. 1450 ( d ), second paragraph.) SECTION 4. Delivery Essential to Issue . Delivery is essential to constitute an issue of bonds. SECTION 5. Bond Secured by a Mortgage . In cases where a bond and a mortgage are simultaneously issued and executed, the bond having been secured by the mortgage, only one stamp tax on both the bond and the mortgage, shall be collected, said tax to be the highest rate which can be imposed on the bond or on the mortgage. In other words, if the tax that can be collected on the bond under subsection ( a ) of section 1449 is greater than that which can be realized on the mortgage under subsection ( w ) of the same section, the tax to be imposed is the former, and in the contrary case, the latter. SECTION 6. Transfer of Bonds, Debentures, etc. No documentary stamp tax accrues on mere transfers of bonds, debentures, or certificates of indebtedness issued by any association, company, or corporation, but where the transfer of the bonds carries with it the issuance of new bonds in the name of the transferee to replace the old ones, the tax imposed on the issuance of bonds should be paid. SECTION 7. Interim Certificates and Temporary Bonds . Interim certificates or temporary bonds issued in lieu of definitive bonds are taxable, but no additional tax is required upon the issue of the permanent or definitive bonds, which however, should bear notation of the fact that stamps in the proper amount were duly attached to the interim certificates. HSTAcI SECTION 8. Scrip-dividend Certificates or Warrants. Scrip-dividend certificates or warrants are taxable as certificates of indebtedness. SECTION 9. Certificates of Indebtedness . The term "certificates of indebtedness" includes only instruments having the general character of investment securities as distinguished from instruments evidencing debts arising in ordinary transactions between individuals. SECTION 10. Renewals of Bonds, Debentures, etc. Every renewal of bonds, debentures, or certificates of indebtedness mentioned in this subsection shall be taxed as a new issue. SECTION 11. Bonds Executed in a Foreign Country. Bonds executed in a foreign country by foreign corporations certified to by trustee in the Philippine Islands given for part of the purchase price of goods located in a foreign country and delivered in the Philippine Islands are subject to tax. SECTION 12. Bonds, Notes, etc., Secured by Mortgage, Pledge, or Deed of Trust. According to the second paragraph of section 1450 ( d ) of the Administrative Code when any bond, note, or other obligation (including debentures and certificates of indebtedness) is secured by mortgage, pledge, deed of trust, or by the assignment or transfer of any documentary security, one tax only shall be collected upon such papers, such tax to be at the highest rate imposed upon such mortgage, bond, note, obligation or other document, as the case may be. CERTIFICATES OF STOCK On every original issue, whether on organization or on reorganization, of certificates of stock by any such association, company, or corporation, on each two hundred pesos, or fractional part thereof, of the face value of such certificate, twenty centavos. (Section 1449 ( b )). SECTION 13. Certificates of Stock Issued to Replace Prior or Original Certificates . No documentary stamp tax is due upon certificates of stock issued to replace prior or original certificates, provided the new certificates are issued to the same person, inasmuch as the issuance of these new certificates is not an original issue either on organization or reorganization. However, if such issue is to split up a certificate of higher value, of say P1,000 par value, into two certificates of P500 each, inasmuch as the tax is on each P200 or fractional part thereof, there would be an additional tax of 20 centavos due on account of the one hundred in the share of P500 each. This tax should be paid and evidenced by the affixture of a 10-centavo stamp to the stubs of each of the 500-peso certificates, with a note on each certificate to the effect that the tax was originally paid on the 1,000-peso certificate and that the amount of 10 centavos covers the difference. SaHIEA SECTION 14. Paid-up Stock and Stock Paid for in Installments. Certificates issued for stock paid for at full face value are subject to the tax in paragraph ( b ) of section 1449 of the Administrative Code; and there shall be paid upon agreements entered into between the association or corporation and any person binding himself to purchase stocks by installments the documentary tax imposed in paragraph ( c ) of that section. SECTION 15. Issuance of New Certificates of Stock. If the calling of the unpaid subscribed capital stock is because of the reorganization of a company, the new issue of stock is taxable under this subsection and documentary stamps in the sum of 20 centavos for each P200 or fractional part of the face value of the certificates should be affixed to the stubs of the certificates of stocks issued. In case certificates of stock already taxed as above noted are replaced by new certificates without any change in the face value and ownership thereof, no documentary stamp tax is due upon such new certificates. However, it should be noted on the new certificates of stock that the proper documentary stamp has been affixed to the stubs of the original certificates. SECTION 16. Stock Certificates Replaced by Several Certificates of Equal Combined Value. In cases where the owner of say one thousand shares of stock in a corporation evidenced by a single stock certificate desires to have said shares evidenced by ten certificates of one hundred shares each, no sale or transfer of ownership being made and no consideration passed by or to anyone, the old certificate should be surrendered to the secretary of the corporation and by him retained in his permanent records and a note made on each of the ten certificates as follows: "Issued as partial substitute for certificate No. _______ covering one thousand shares; proper documentary stamp attached to the stub of the original certificate." SECTION 17. Sale of a Portion of a Stock Certificate. Where the owner of one thousand shares evidenced by one stock certificate sells five hundred shares to another person the documentary stamps in the proper amount should be affixed to the stub of the certificate for the five hundred shares sold, and, on the new certificate issued to the original owner there should be made a note similar to that mentioned in the preceding paragraph. SECTION 18. Provisional Certificates of Stock Issued in Lieu of Permanent or Regular Definitive Certificates. Provisional certificates of stock issued in lieu of permanent or regular definitive certificates are taxable but no additional tax is required upon the issue of such permanent, regular, or definitive certificates in place of the provisional certificates: Provided, however, That such permanent, regular, or definitive certificates should bear notation of the fact that stamps in the proper amount were duly affixed to the stubs of the provisional certificates. SECTION 19. Affixture of Stamps on Issues of Certificates of Stock . The documentary stamps covering the tax on issues of certificates of stock should be affixed to the stubs of the certificates and not on the certificates themselves. However, a notation should be made on the face of the certificate, preferably by a rubber stamp, substantially as follows: "Documentary stamps to the value of P__________ have been affixed to the stub of this certificate." TRANSFER OF CERTIFICATES OF STOCK, ETC. On all sales, or agreements to sell, or memoranda of sales, or deliveries, or transfer of bonds, duebills, certificates of obligation, or shares or certificates of stock in any association, company or corporation, or transfer of such securities by assignment in blank, or by delivery or by any paper, or agreement, or memorandum, or other evidence of transfer or sale, whether entitling the holder in any manner to the benefit of such bonds, duebills, certificates of obligation or stock, or to secure the future payment of money, or for the future transfer of any bond, duebill, certificate of obligation or stock, on each two hundred pesos, or fractional part thereof, of the par value of such bond, duebill, certificate of obligation or stock, four centavos. (Section 1449 ( c ), Act No. 2711, as amended by Sec. 1, Act No. 3047). SECTION 20. Transfers of Shares of Stock. Transfers of shares of stock in a corporation organized under the laws of the Philippine Islands, even though effected and recorded in a foreign country or beyond the territorial limits of the Philippine Islands, are nevertheless subject to the stamp tax, so long as such transfers have actually been made and are recorded in the books of the corporation. SIcCTD SECTION 21. Exchange of Certificates of Stock . No documentary stamp tax is due and collectible on an exchange of a number of shares of 4 per cent accumulated preferred stock for a like amount of 6 per cent accumulated preferred stock so long as there is not a change in the ownership of said shares. SECTION 22. Transfer of Certificates of Stock from Trustee to Another. If by the transfer of certificates of stock from a resigned trustee to a newly appointed trustee such certificates of stock remain in the name of the cestui que trust or the resigned trustee so that the new trustee is constituted mere depositary of the stock, such transfer is not taxable. If, however, the transfer carries a change in the name appearing in the certificates of stock or in the books of the corporation or company issuing same, the transfer is taxable under section 1449 ( c ) of the Administrative Code. SECTION 23. Pledging of Certificates of Stock as Security for Loans . The pledging and subsequent redemption and return constitute two separate transactions, each of which is subject to tax under section 1449 ( c ) mentioned in the foregoing paragraph. SECTION 24. Agreements to Sell Also Subject to Tax. Under this subsection not only actual sales or transfers of stock are taxable but also agreements to sell such stock or future transfers thereof such as in the case of contracts of subscription of shares of stock or executory contracts for the sale or transfer of shares of stock. ( See Sec. 14 of these Regulations.) SECTION 25. Stamp Tax on Transfers of Certificates to be Affixed to Books of Corporations . Under the provisions of section 1451, second paragraph, of the Administrative Code, in connection with section 35 of Act No. 1459, the Corporation Law, documentary stamps covering the tax on transfers of certificates of stock should be affixed to the books of the corporation where the transfer is recorded for the reason that the only conclusive evidence of a valid transfer of shares of stock is shown in the entries and notations effected upon the books of the company showing the names of the parties to the transactions, the date of the transfer, the number of the certificate, and the number of shares transferred. FOREIGN BONDS AND DEBENTURES, ETC. On all bonds, debentures, certificates of stock, or certificates of indebtedness issued in any foreign country there shall be paid by the person here selling or transferring the same, such tax as is required by law on similar instruments when issued, sold or transferred in the Philippine Islands. (Section 1449 ( d ).) ETHSAI SECTION 26. Sales of Bonds, Debentures, etc., Issued in a Foreign Country. Under this paragraph, bonds, debentures, certificates of indebtedness or certificates of stock issued in a foreign country but sold in the Philippine Islands, are subject to the tax imposed upon similar instruments when issued, sold, or transferred in the Philippine Islands. SECTION 27. Bonds Secured by Mortgage. ( See Sec. 5.) CERTIFICATES OF PROFITS AND TRANSFERS THEREOF On all certificates of profits, or any certificate or memorandum showing interest in the property or accumulations of any association, company, or corporation and on all transfers of such certificates or memoranda, on each two hundred pesos or fractional part thereof, of the face value of such certificate or memorandum, two centavos. (Section 1449 ( e ).) SECTION 28. Sale of Participations in a Partnership. Under this subsection documents of sales of participations in a partnership are subject to tax because such documents are considered as memoranda showing interest in the property or accumulations of associations, companies or corporations. SECTION 29. Coupons Attached to Certificates of Stocks. Coupons attached to certificates of stocks are certificates of profit, and at maturity, or when detached, should each bear the stamp provided in section 1449 ( e ) of the Administrative Code. SECTION 30. Business Property Investment Bond. A business property investment bond wherein it is certified that the holder thereof is the owner of an interest in certain specified real property, legal title to which has previously been conveyed to a trustee, and whereby the corporation issuing the same agrees to manage the property and distribute the proceeds in a certain manner, is not subject to tax as a bond, debenture, or certificate of indebtedness, but is subject to tax as a certificate of interest in property issued by a corporation. CHECKS, DRAFTS, AND CERTIFICATES OF DEPOSIT On each bank check, draft, or certificate of deposit, not drawing interest, or order for the payment of any sum of money drawn upon or issued by any bank, trust company, or any person or persons, companies, or corporations, at sight or on demand, two centavos. (Section 1449 (f) .) HEASaC SECTION 31. To What Section 1449 (f) Refers. Section 1449 (f) of the Administrative Code above quoted applies only to inland checks, drafts or certificates of deposit not drawing interest, or order for the payment of any sum of money drawn upon or issued by any bank, trust company, or any person or persons, companies, or corporations, at sight or on demand. SECTION 32. Checks, Drafts, etc., Drawn Outside of the Philippine Islands . Checks, drafts, etc., drawn outside of the Philippine Islands, and by their terms payable also at some point outside said Islands, are subject to tax imposed by the section mentioned in the preceding paragraph, if cashed or negotiated at any point within the Philippine Islands. SECTION 33. Copies of Checks. Such copies, when unsigned and undelivered or retained, as in the case of stubs, are considered as records only, and are not subject to documentary stamp tax. IcHTCS SECTION 34. Notes or Memorandum Orders. Agents of commercial houses who in exchange for money received, issue notes or memorandum orders upon another agent of the same firm to be exchanged by him for a draft should pay the documentary stamp tax provided in paragraph (f); to the draft issued there should be affixed documentary stamps in payment of the tax provided in paragraph (f) or paragraph (g) of this section, as the case may be. SECTION 35. Certificates of deposit issued by local banks to the Treasurer of the Philippine Islands for trust funds deposited by the said treasurer are subject to the documentary stamp tax provided in paragraph (f) or (g) of this section, as the case may be. ( See Sec. 38 for distinction.) SECTION 36. Certificates Furnished by an Employer of Labor . Certificates furnished by an employer of labor to his employees showing how much work an employee has performed and the amount of wages due him are not subject to the documentary stamp tax under paragraphs (f) or (g) of this section as orders for the payment of money. SECTION 37. Trade Acceptances . The so-called "trade acceptances" are taxable in the same manner as time drafts. SECTION 38. Checks, Drafts, and Bills of Exchange . The rule to be followed in determining whether paragraph (f) or paragraph (g) of this section covers a particular case is as follows: If the order for the payment of money does not draw interest and is payable at sight or on demand, paragraph (f) applies. If such order draws interest or is payable otherwise than at sight or on demand, paragraph (g) applies. In cases where checks are postdated, they are subject to tax as promissory notes, under paragraph (g) . INLAND BILLS OF EXCHANGE, DRAFTS, AND CERTIFICATES OF DEPOSIT On all bills of exchange (between points within the Philippine Islands), drafts, and certificates of deposit drawing interest, or orders for the payment of any sum of money otherwise than at sight or on demand, and on all promissory notes, except bank notes issued for circulation, and on each renewal of any such note, on each two hundred pesos, or fractional part thereof, of the face value of any such bill of exchange, draft, certificate of deposit, or note, two centavos. (Section 1449 ( g ).) TIAEac SECTION 39. Definition of "Bill of Exchange" . The term "bill of exchange" denotes checks, drafts, and all other kinds of orders for the payment of money, payable at sight or on demand or after a specific period after sight or from a stated date. SECTION 40. "Promissory Note", Defined. A promissory note is an unconditional promise in writing made by one person to another signed by the maker engaging to pay on demand or at a fixed or determinable future time, a sum certain in money to such other person or to order or to bearer, free from restrictions as to registration or transfer and usually without coupons. SECTION 41. "Vales". A "vale" which contains all the necessary elements of a promissory note is subject to the documentary stamp tax as such a note and under the same condition in which the latter becomes liable to the tax. SECTION 42. Responsibility for Payment of Tax on Promissory Notes . The person who signs or issues a promissory note and any person transferring or using a promissory note can be held responsible for the payment of the documentary stamp tax. SECTION 43. Promissory Notes Issued Directly by a Foreign Government. Promissory notes issued directly by a foreign government and placed in this country for sale or negotiation are exempt from tax. SECTION 44. Tax Also Due on Renewals. The tax under this section is not merely on the bill of exchange, draft, and certificates of deposit drawing interest, or orders for the payment of any sum or money otherwise than at sight or on demand and on all promissory notes, but also on each and every renewal of any such document. The tax on such renewal should be at the same rate as the tax on the original document. FOREIGN BILLS OF EXCHANGE INCOMING Upon any acceptance or payment upon acceptance of any bill of exchange or order for the payment of money purporting to be drawn in a foreign country but payable in the Philippine Islands, on each two hundred pesos, or fractional part thereof, of the face value of any such bill of exchange or order, or the Philippine equivalent of such value, if expressed in foreign currency, two centavos. (Section 1449 ( h ).) SECTION 45. "Bill of Exchange", Defined. ( See Sec. 39.) AEaSTC SECTION 46. Bill of Exchange, etc. When any bill of exchange or order for the payment of money drawn in a foreign country but payable in this country whether at sight or on demand or after a specified period after sight or from a stated date, is presented for acceptance or payment, there must be affixed upon acceptance or payment documentary stamp equal to P0.02 for each P200 or fractional part thereof. SECTION 47. Acceptance of Bill of Exchange . A bill of exchange should be stamped at the time of its acceptance or upon payment upon acceptance. In case of fluctuation of values, this office will accept as conclusive for internal revenue purposes the value of the foreign money exchange included, at the time of the acceptance of the bill. No refund of additional taxes will be made. Bills of exchange should be stamped at their face value. Interests, commissions, stamps, etc., should not be included. SECTION 48. Reacceptance of Foreign Bill of Exchange . Documentary stamps in the proper amount should be affixed to a bill of exchange drawn in a foreign country but payable in the Philippine Islands upon its reacceptance by the same person who first accepted it or by another, though stamps were affixed upon its first acceptance. The tax is thus due on every acceptance. FOREIGN BILLS OF EXCHANGE AND LETTERS OF CREDIT OUTGOING On all foreign bills of exchange and letters of credit (including orders, by telegraph or otherwise, for the payment of money issued by express or steamship companies or by any person or persons) drawn in but payable out of the Philippine Islands, in a set of three or more according to the custom of merchants and bankers, on each two hundred pesos, or fractional part thereof, of the face value of any such bill of exchange or letter of credit, or the Philippine equivalent of such face value, if expressed in foreign currency, four centavos. (Section 1449 ( l ).) SECTION 49. Drafts Drawn Against a Letter of Credit . A documentary letter of credit is opened for gold dollars in the United States in favor of a party in the Philippine Islands. The party in the Philippine Islands draws drafts in gold dollars against the letter of credit and presents them to a local bank with all documents attached. The local bank advances in pesos the value of the drafts, drawn by the party in the Philippine Islands at the current buying rate for the day and sends the drafts to the United States office or correspondent of that bank to be accepted paid by the drawee there. The drawee pays in the United States office or correspondent and on the date of his payment the United States office or correspondent credits the proceeds to the account of the local bank with it. Under the aforementioned statement of facts the drafts are to be considered as having been drawn in the Philippine Islands and payable in a foreign country, taxable under the provisions of subsection ( i ) of section 1449 of the Administrative Code. SECTION 50. Basis of Tax in Case of Telegraphic Transfers. The basis of the tax in the case of telegraphic transfers or orders for the payment of money drawn in but payable out of the Philippine Islands should be the face value of such telegraphic transfers or orders computed, if expressed in a foreign currency, with the rate of exchange taken into consideration. Example: Inasmuch as a telegraphic transfer for P50,000 gold is not always equivalent to P100,000 Philippine currency, the latter cannot be considered as the face value of a telegraphic transfer drawn in gold so that if the current rate of exchange at the time of sending such telegraphic transfer or order is 10 per cent the basis would be P110,000 and not P100,000. TADaES SECTION 51. What may be Regarded as Telegraphic Transfer . If a local bank cables to a certain bank in a foreign country with which bank said local bank has a credit, and directs that foreign bank to pay to another bank or person in the same locality a certain sum of money, the document for and in respect of such transaction will be regarded as a telegraphic transfer, taxable under the provisions of section 1449 ( i ) of the Administrative Code. POLICIES OF INSURANCE LIFE On all policies of insurance, or other instruments by whatever name the same may be called whereby any insurance shall be made or renewed upon any life or lives, on each two hundred pesos, or fractional part thereof, of the amount insured by any such policy, ten centavos. (Section 1449 (j) .) SECTION 52. "Other Instruments", Defined. The term "other instruments" includes any instrument by whatever name the same is called whereby insurance is made or renewed, i.e. , by which the relationship of insurer and insured is created or evidenced, whether it be a letter of acceptance, cablegrams, letters, binders, certificates, covering notes, or memoranda. SECTION 53. Insurance Policies . Insurance policies are issued in the place where delivered to the person insured. Therefore, the documentary stamp tax is not due on insurance policies issued by a Philippine company to persons in other countries. SECTION 54. Tax Also Due on Renewals . The tax under this section is collectible not only on the original policy or contract of insurance but also upon the renewal of the policy or contract of insurance. SECTION 55. Assignment or Transfer of Policy or Contract of Insurance. In accordance with the provisions of subsection ( z ) of section 1449 of the Administrative Code every assignment or transfer of a policy or contract of insurance is subject to tax at the same rate as that imposed on the original instrument. SECTION 56. Contract of Reinsurance . A contract of reinsurance is also subject to tax inasmuch as the original insurer insures his risk to the reinsurer so that the reinsurance contract falls within the provisions of this subsection. SaCDTA MARINE, INLAND, AND FIRE INSURANCE POLICIES PROPERTY On all policies of insurance or other instruments by whatever name the same may be called, by which insurance shall be made or renewed upon property of any description, including rents or profits, against peril by sea or on inland waters, or by fire or lightning, on each four pesos, or fractional part thereof, of the amount of premium charged, two centavos. (Section 1449 ( k ).) SECTION 57. Policy of Insurance . Under the Act of Congress of October 22, 1914, a policy of insurance issued by a foreign company and delivered in the United States on property in the latter country, is subject to the documentary stamp tax. It follows, therefore, that a policy of insurance issued by a foreign company and delivered in the Philippines on property in this country is subject to the payment of the documentary stamp tax at the rate of 2 centavos for every P4, or fractional part thereof of the premium charged. SECTION 58. Issuance of Insurance Policy . In case where the insurance company accepts the insurance on an entire cargo and a policy is duly issued, and a portion of the risk is reinsured in another company and another policy is issued for the reason that the former does not want to assume all responsibility, there are two policies of insurance, the original policy issued by the former company and the reinsurance policy issued by the latter, and for the purposes of the documentary stamp tax, both the original policy and the reinsurance policy are subject to the tax as the law provides that whenever a policy of insurance is issued, the tax accrues. SECTION 59. Transfer of a Policy of Insurance . Stamps upon the assignment or transfer of any mortgage, lease, or policy of insurance, shall be the same as that required upon the original instrument. However, if the assignment or transfer is in the nature of a pledge of the insurance policy to secure a loan, the above ruling will not apply. SECTION 60. Stamp Tax on Insurance Policies Covering Government Property. No distinction is made by the law between insurance of Government and other property, and, the tax being imposed on the insurance policies themselves, it cannot be considered as a tax on the Government when its property happens to be the property insured. SECTION 61. "Premium Charge", Defined. The term "premium charge" means the total premium payable during the life of a contract of insurance and includes any additional assessment or charge in the nature of a premium which may be assessed or charged during the life of a contract of insurance, whether payable in one sum or in installments and however paid (and though never paid if the contract of insurance be delivered and accepted or otherwise becomes binding upon the insurer). The term "premium" means the agreed price for assuming and carrying the risk. It includes all that is received by the underwriter therefor and is in fact the total consideration receivable for underwriting the risk, whether in one sum or in installments, during the life of the policy. SECTION 62. Persons Liable . The insurer, the agent or sub-agent, or broker, effecting, accepting, placing or soliciting the insurance and also the insured are liable for the tax. ASHECD SECTION 63. All the Instruments Must Bear the Stamps. ( a ) The stamp must be affixed to the first instrument by which the insurance is made or renewed, i.e. , by which the relationship of insurer and insured is created or evidenced, whether it be a letter of acceptance, cablegram, or other instrument by whatever name called. ( b ) In the case of so-called "open policies" or "open cargo covers", where the amount of the premium is not definitely determined at the time of the issuance, the stamps may be affixed to the receipts for the monthly or other payments if proper notation be made upon such receipts identifying the original instruments to which they apply. A cross reference or notation should also be made on the original instruments to which the stamps affixed to the receipts refer as part payment of the documentary tax due on said instruments. ( c ) In the case of a binder or other instrument whereby insurance is made or renewed, issued without agreement as to the premium to be charged stamps must be affixed when the amount of the premium is determined. SECTION 64. Subsections (j) and (l) of 1449 Apply. The other rulings regarding insurance generally mentioned under subsections (j) and (l) of this section (1449) apply also to this subsection. INDEMNITY BONDS, OBLIGATIONS, AND UNDERTAKINGS On all policies of insurance or bonds or obligations of the nature of indemnity for loss, damage, or liability made or renewed by any person, association, company, or corporation transacting the business of accident, fidelity, employer's liability, plate glass, steam boiler, burglar, elevator, automatic sprinkler, or other branch of insurance (except life, marine, inland, and fire insurance), and on all bonds, undertakings, or recognizances conditioned for the performance of the duties of any office or position, for the doing or not doing of anything therein specified, and on all obligations guaranteeing the validity or legality of any bonds or other obligations issued by any province, municipality or other public body or organization, and on all obligations guaranteeing the title to any real estate, or guaranteeing any mercantile credits, which may be made or renewed by any such person, company, or corporation, on each four pesos, or fractional part thereof, of the premium charged, two centavos. (Section 1449 ( l ).) SECTION 65. Bonds. Bonds made or renewed by any person, association, company or corporation transacting the business of accident, fidelity, employer's liability, plate glass, steam boiler, burglar, elevator, automatic sprinkler, or other branch of insurance (except life, marine, inland, and fire insurance), conditioned for the performance of the duties of any office or position and for the doing or not doing of anything therein specified are subject to the documentary stamp tax at the rate of 2 centavos for each P4 or fractional part thereof of the premium charged, under the provisions of section 1449 ( l ) of the Revised Administrative Code. Such bonds when signed by the principal obligor will also be subject to the 50 centavos documentary stamp tax as provided in paragraph ( n ) of the same section of the Code. HDAaIS SECTION 66. Bonds Required in Judicial Proceedings . If bonds required in judicial proceedings are executed or renewed by persons, associations, companies, or corporations transacting the business of accident, fidelity, or guaranty insuranceship, or other branch of the insurance business, except life, marine, inland and fire insurance, said judicial bonds, although exempt from the documentary stamp tax as provided in subsection ( n ) of section 1449 of the Administrative Code, are, nevertheless, subject to that imposed in subsection ( l ) of the same section, consisting of a tax of 2 centavos on each P4, or fractional part thereof, of the premium charged. If, however, the judicial bonds above-mentioned are executed by persons or corporations not engaged in the business of accident, fidelity or guaranty insuranceship as above defined, and for no compensation, no documentary stamp tax shall accrue thereon. (General Circular No. 39, Oct. 3, 1919.) SECTION 67. When a Premium is Charged Upon Any Bond or Policy . When a premium is charged upon any bond or policy, a statement must be made on the face of such bond or policy showing the rate and amount of premium charged, and bonding companies or other persons executing such bonds or policies must affix thereto the necessary amount of stamps, based on the premium charged, cancelling the same. The renewal or continuance certificate or other paper showing the renewal or continuance of such bond or policy or the receipt or other paper showing the payment of any premium or charge for the renewal or continuance of such bond or policy must also contain on the face thereof a statement showing the rate and amount of the premium charged and collected, and the bonding company or person issuing or executing such certificate or paper must affix thereto the necessary amount of stamps, based upon the premium charged, cancelling the same. ANNUITIES On all policies of annuities, or other instruments by whatever name the same shall be called, whereby an annuity may be made, transferred, or redeemed, on each two hundred pesos, or fractional part thereof, of the capital of the annuity, or should this be unknown, then on each two hundred pesos, or fractional part thereof, of thirty-three and one-third times the annual income, ten centavos. (Section 1449 ( m ).) SECTION 68. Censo . A censo or annuity is constituted when any real property is subject to the payment of an annual income in consideration of a cash payment, or of the transfer of the full or partial ownership of the estate subjected to the charge. (Article 1604, Civil Code.) A contract constituting a censo as hereinbefore defined, whether it be called a policy of annuity or by whatsoever name is subject to tax under this section. Under article 1802 of the Civil Code an aleatory contract of annuity may be entered into to bind the debtor to pay a pension or annual income to one or more specified persons for life in return for a principal in personal or real property, the ownership of which is at once transferred to the debtor, charged with the payment of the income. An annuity may also be constituted on the life of the person who pays the capital, on that of a third person, or on the lives of several persons. It may also be constituted in favor of the person or persons for whose lifetime it is granted, or in favor of another or other different persons. Upon transfer either by assignment or indorsement of a policy or contract of annuity, as hereinbefore described or upon redemption of the annuity, the tax fixed in this subsection should be paid. ISCDEA SURETY BONDS On each bond for indemnifying any person, firm, or corporation who shall become bound or engaged as surety for the payment of any sum of money or for the due execution or performance of the duties of any office or position or to account for money received by virtue thereof, and on all other bonds of any description, except such as may be required in legal proceedings or are otherwise provided for herein, fifty centavos. (Section 1449 ( n ).) SECTION 69. Surety Bonds . Bonds should be stamped at the rate of 50 centavos for each bond, in addition to 2 centavos for each P4 or fractional part thereof, of the premium charged in case the surety on the bond is a bonding or surety company. ( See also Sec. 67.) SECTION 70. Bail Bonds . There is no documentary stamp tax on such bonds, because they are required in judicial proceedings. ( See Sec. 1450 ( d ) of the Administrative Code.) SECTION 71. Bonds Required by Court of a Person with Whom Stolen Property is Deposited. Under the provisions of section 1450, such bonds are not subject to tax. SECTION 72. Customhouse Broker's Bond. Regardless of the amounts of such bonds the stamp tax in this paragraph should be paid. SECTION 73. Indemnity Bonds. Bonds furnished to protect the Government in cases of issuance of duplicate checks, check vouchers, or warrants are subject to the documentary stamp tax of 50 centavos unless the check, check vouchers, etc., the loss of which makes necessary the furnishing of bond for the protection of the Government is lost before ever having reached the possession of the payee and not by any fault or negligence of the payee himself. If lost through the fault or negligence of an officer of the Government or through any cause not traceable to the payee, no stamp will be required, but notation of such cause should appear on the bond in lieu of the stamp. SECTION 74. Plaintiff's Bonds for Temporary Attachment. These bonds are not subject to the documentary stamp tax; nor do any taxes accrue on the certificates of oaths on such bonds. DIHETS CERTIFICATES On each certificate of damage, or otherwise, and on every other certificate or document issued by any customs officer, marine surveyor, or other person acting as such, and on each certificate issued by a notary public, and on each certificate of any description required by law, or by rules or regulations of a public office, or which is issued for the purpose of giving information, or establishing proof of a fact, and not otherwise specified herein, twenty centavos. (Section 1449 ( o ).) SECTION 75. Definition of Certificates. A certificate is a statement in writing by a person having a public or official status concerning some matter within his knowledge or authority; a writing by which testimony is given that a fact has or has not taken place. (Regulations No. 2, p. 14.) SECTION 76. Certificates Which are Taxable under This Act. Only those certificates issued by a public official or person acting in a public capacity are subject to the documentary stamp tax. SECTION 77. Certificates Issued by Customs Officers, Marine Surveyors. Under this section is taxed also a certificate issued by customs officers, marine surveyors, or other persons acting as such to the effect that certain goods or portion thereof are lost at sea, because that is a certificate of damage. The tax under this subsection is in addition to such customs documentary tax as the Bureau of Customs may require in such cases. SECTION 78. Liability of Notaries Public and Other Officers Authorized to Administer Oaths . A notary public or other officer authorized to administer oaths is liable for violation of section 1452 of the Administrative Code, as amended by section 2 of Act No. 2835, penalized under section 2741 of the same Code, when such notary public or officer adds his jurat or acknowledgment to any document subject to the documentary stamp tax to which the required documentary stamps have not been affixed and cancelled. SECTION 79. Certificates of Acknowledgment Signed by a Notary Public. Articles of incorporation are not subject to the 20-centavo documentary stamp tax but the certificate of acknowledgment signed by the notary public is subject to the 20-centavo documentary tax, for the affixture of which the notary himself is principally responsible and not the incorporators. aCASEH SECTION 80. Certificates of Acknowledgment to Deeds, Leases, Powers of Attorney, Mortgages . Certificates of acknowledgment to deeds, leases, powers of attorney, mortgages, or any other documents, when such certificates are a necessary part of the instrument, are exempt from the tax in this paragraph. One tax only accrues on such instruments. SECTION 81. Powers of Attorney. Notarial certificates attached to powers of attorney are certificates of acknowledgment and not of the administration of oaths and, according to the rule of strict construction of exemptions from taxation, are not included in the exemption provided by section 1450 for certificates of the administration of oaths for use in court. Therefore, such certificates are subject to the documentary stamp tax provided by this paragraph even when designed exclusively for use in court proceedings. SECTION 82. Jurat, Definition of. That part of an affidavit where the officer certifies that the same was sworn to or affirmed before him. SECTION 83. Jurat or Certificate of Oath Administered on Application for Civil Service Examination. The oath on these applications is administered at the instance and for the benefit of the applicant, and should be stamped as required in this paragraph. SECTION 84. Jurat or Certificate of Oath of Office Administered; Government Service . The documentary stamp tax should be paid on the jurat ( a ) where an officer or an employee is entering the service of the Government; ( b ) where the officer or employee having been separated is reentering the Government service. In the case of certificates of officers administering oaths of office to officers or employees already in the Government service upon their assuming other duties in the same office or in another office, or to person accepting positions in the service of the Government without salary, no documentary stamp taxes accrue thereon. SECTION 85. Affidavits Sworn to Before a Notary Public. Under existing laws, with the exceptions specified in section 1450 ( d ) of the Revised Administrative Code, a 20-centavo documentary stamp should be affixed to any affidavit whether in form or otherwise sworn to before a notary public. cAECST SECTION 86. Oaths Administered by Officers under Act No. 2589 . Oaths administered by any officer empowered to administer oaths to persons assigning retirement gratuities under the provisions of Act No. 2589 as amended are also taxed under this section. SECTION 87. Income and Inheritance Tax Returns. Oaths administered by a notary public or other officer empowered to administer oaths to a person filing an income tax return, or of an inheritance tax return are not subject to tax for the reason that they are administered in connection with statements and other compulsory information required of persons by the Government exclusively for statistical purposes and are wholly for the use of the Bureau of Internal Revenue in which the same are filed, such statements or compulsory information being specifically exempted from the payment of the tax under section 1450 ( d ) of the Administrative Code. SECTION 88. Certificates of Oaths of Electors . Section 1450 exempts such certificates from the stamp tax in this paragraph. SECTION 89. Cards of Membership, Reward of Merit, or Identification Issued by Churches to Persons Connected or Identified Therewith. As such cards are used solely for religious purposes from which there is no pecuniary benefit, they are not subject to the stamp tax in this paragraph as certificates. SECTION 90. Certificate of Lost Weights and Measures Tag . The original copy of certificate of lost weights and measures tag should have affixed thereto a 20-centavo documentary stamp. SECTION 91. Certificates or Bills of Sale Issued by a Sheriff to the Purchaser of Personal Property. Such certificate is the document required by law for the transfer to the purchaser of title to the property, and is subject to the tax in this paragraph. SECTION 92. Customhouse Certificates . The tax imposed by this paragraph should be collected in addition to that imposed by sections 284 and 392 of the Customs Administrative Act (No. 355). (1414, Act No. 2711.) (Opinion, Atty.-Gen., Oct. 27, 1904.) SECTION 93. Certificates of Ownership of Real Property. Certificates of ownership of real property should bear the 20-centavo documentary stamp provided for by this paragraph. DHITcS SECTION 94. Certificates of Ownership, Transfer, etc., of Large Cattle Required by the Cattle Registration Law. Certificates of ownership, certificates of transfer, permits for slaughter, and all certificates issued in compliance with the provisions of the Cattle Registration Law, are exempt from the documentary stamp tax, being certificates required by the Government for statistical purposes. SECTION 95. Certificates of Assessed Value of Land Furnished by Provincial or Municipal Treasurers to Clerks of Court. Certificates of assessed value of lands furnished by provincial or municipal treasurers to clerks of court at their request for registration of title to land are subject to the documentary stamp tax of 20 centavos imposed in section 1449 ( o ) of the Administrative Code. SECTION 96. Certificates of Bonds . Such certificates containing special information not absolutely necessary to complete the instrument are subject to the documentary stamp tax in this paragraph. In case of a fidelity bond, the certificate is a necessary part thereof and therefore exempt. SECTION 97. Certificates issued by the Boards of Pharmaceutical, Medical, and Dental Examiners are not subject to the documentary stamp tax prescribed in this paragraph. SECTION 98. Certificates issued by the City of Manila and municipal corporations are subject to the documentary stamp tax imposed by this paragraph. SECTION 99. Certificates of Birth and Death. ( a ) Birth and death certificates required by law or issued under rules and regulations of the Board of Health are not subject to documentary stamp taxes; ( b ) but certificates of death, birth, or of baptism issued by parish priests or ministers from church records for the purpose of proof of paternity and filiation of legitimate children, or by doctors for the benefit of the person applying for same, are subject to the tax provided by this paragraph; and ( c ) copies of birth and death records furnished by municipal secretary to any person other than a Government official in his official capacity are subject to the tax provided by this paragraph. SECTION 100. Certificate of Lost Tax-Receipt. To the original copy of this certificate, there should be affixed a 20-centavo documentary stamp. aCTHDA SECTION 101. Certificates of Valuation of Property Furnished by Provincial Treasurer . If such certificates are furnished at the instance of the interested party for his use and benefit the documentary stamp tax should be paid; when accomplished wholly for the use of the Government such documents are not subject to tax. SECTION 102. Complaints in Civil or Criminal Proceedings . Complaints and other pleadings and documents in support of same in civil or criminal proceedings are exempt from stamp taxes. SECTION 103. Certificates Issued by the Bureau of Commerce and Industry . All licenses and other certificates issued to foreign corporations by the chief of the division of archives, patents, copyrights and trade-marks of said Bureau under the provisions of section 68 of Act No. 1459 are subject to the documentary stamp tax in this paragraph. SECTION 104. Enlistment Papers of Soldiers of the Philippine Constabulary. These documents are exempt from the documentary stamp tax. SECTION 105. Landing Certificates Issued by the Collector of Customs as Acting United States Consular Agent. These certificates are not subject to the stamp tax imposed in this paragraph. SECTION 106. Certificates of Guarantor on Contractor's Bond (Bureau of Public Works) . As such certificates contain special information which is not absolutely necessary to complete the bond, each of the certificates of guarantor, when made out, is subject to this tax of 20 centavos. SECTION 107. Marriage Certificates, Certificates of Consent to Marriage, etc. Marriage certificates, certificates of consent to marriage, and all certified copies thereof when signed or issued by a judge, justice of the peace, priest, or minister of the gospel of any denomination, or any person authorized to perform marriage ceremonies in the Philippine Islands should bear the 20-centavo documentary stamp provided in this paragraph, except the certificate of marriage furnished in each case by the official, priest, or minister performing the ceremony to the municipal secretary or other Government official by virtue of a provision of law requiring him so to do. The latter being designed exclusively for the use of the Government for statistical purposes are exempt from this tax by the terms of section 31 of Act No. 2339 (now 1450 of Act No. 2711). IcHSCT Copies retained for private records of the ministers or other person performing the ceremony are not certificates but merely record copies, and are not subject to the documentary stamp tax. SECTION 108. Certificates Issued by Sheriff. Certificates, issued by the sheriff of the sale at public auction of real property by virtue of an order of execution in favor of the purchaser or purchasers reserving to the owner the right of legal redemption within one year, in accordance with the Code of Civil Procedure, are subject. SECTION 109. Medical Certificates Regarding Physical Condition. Medical certificates containing a statement of the physical condition of any person are not subject to this tax. SECTION 110. Reports of birth, deaths, and marriages issued under rules and regulations of the Board of Health are exempt under the provisions of section 1450 of Act No. 2711. SECTION 111. Reports of Missing Mail (Bureau of Posts Form No. 565). Such reports are made for the use and benefit of the person making them. The jurat is therefore subject to the tax in this paragraph. SECTION 112. Sworn Statements by Constabulary Officers under Instructions Contained in the Constabulary Manual, and the Oath or Jurat Thereon. Such sworn statements are intended for use by the various prosecuting attorneys for the Government in connection with criminal actions that may thereafter be brought and come clearly within the exemption provided by section 1450. The jurat of the notary or other officer administering the oath, upon such statements is exempt under the provisions of the same section from the stamp tax. SECTION 113. Permits for the Possession of Firearms. The permit or certificate authorizing the possession of firearms should bear a 20-centavo documentary stamp under the provisions of this paragraph. An officer of the Government obtaining a firearm permit, or a renewal thereon, other than in his official capacity and under rules and regulations of the office with which he is connected, should affix and cancel documentary stamps upon the certificates in the same manner as persons not employed in the Government service. HDcaAI SECTION 114. Affidavits of Witnesses Mentioned in B.I.R. General Circular No. 62. In accordance with the provisions of section 1149 ( o ) of the Administrative Code, a documentary stamp tax of 20 centavos should be paid on each of the affidavits of witnesses submitted by a petitioner for a change of name or age in his cedula certificates mentioned in section 1 of General Circular No. 62 of the Bureau of Internal Revenue. Provincial treasurers or deputy provincial treasurers should not forward to this Office any petition for a change of name or age on cedulas unless the stamp tax required by law is first duly paid. SECTION 115. Certificates Appended by Municipal Secretaries to Copies of Municipal Records. Certificates appended by municipal secretaries to copies of municipal records issued in accordance with section 2213 of the Revised Administrative Code are subject to tax imposed under this subsection. SECTION 116. Certificates Issued for the Benefit and at the Instance of Private Persons. It is a general rule that if a certificate is issued at the instance and for the exclusive use of a private person certificates even if issued by the Government or any branch thereof are subject to the tax. WAREHOUSE RECEIPTS On each warehouse receipt for property held in storage in a public or private warehouse or yard for any other person than the proprietor of such warehouse or yard himself or some employee of his engaged in and about the same, twenty centavos. (Section 1449 ( p ).) SECTION 117. Provisional or Memorandum Receipts for Partial Delivery of Rice at a Warehouse. Provisional or memorandum receipts for partial delivery of rice at a warehouse are not warehouse receipts subject to a documentary stamp tax. Forms furnished by a warehouseman for each load of rice delivered to the warehouse to enable the owner of the rice and the owner of the warehouse to keep a check on the partial deliveries so that they may compute the total amount of rice delivered for the issuance of the warehouse receipt, are simply memoranda which are not subject to the documentary stamp tax. SECTION 118. Contracts or Receipts for the Storage of Lumber. Contracts or receipts for the storage of lumber in lumber yards complying substantially with the provisions of section 2 of Act No. 2137 (the Warehouse Receipts Act) are taxable under this section. SECATH SECTION 119. Storage Need Not be Made in a Public Warehouse . It is not necessary that the storage of property be made in a public warehouse or that the person or company issuing the warehouse receipt or signing the contract for storage be publicly engaged in the warehousing business. It sufficient for the imposition of the tax under this subsection that a receipt is issued for the warehousing of property in public or private warehouse or yard for a compensation. BILLS OF LADING EXPORT On each set of bills of lading or receipts (except charter party) for any goods, merchandise, or effects of greater value than five pesos, to be exported from a port in the Philippine Islands to any foreign port, ten centavos. (Section 1449 ( q ).) SECTION 120. "Bill of Lading", Defined. A bill of lading is defined as "a contract by which the carrier agrees to deliver the goods entrusted to him for transportation to the person named therein." ( National Bank of Chester vs. Atlanta & C.A.L. Ry. Co., 25 S.C., 216.) If the carrier does not assume the obligation to transport the goods covered by the bill of lading, the note is not a bill of lading and hence it is not subject to the documentary stamp tax. SECTION 121. Basis of the Tax and Affixture of Stamps. Bills of lading are exempt from the documentary stamp tax imposed by paragraphs ( q ) and ( r ) of section 1449 of the Administrative Code when the value of the goods shipped is P5 or less. Unless the bill of lading states that the goods are worth P5 or less, it must be held that the tax is due, and internal revenue officers will see to it that the tax is paid in all cases where the bill of lading does not state that the shipment is worth P5 or less. The documentary stamp shall be affixed to the copy of the bill of lading retained by the carrier or carrier's agent at the shipping point except in the case of transportation companies which have a central office in the Philippine Islands, and which require their agents to furnish the said office with a copy of each bill of lading. The stamp shall in such case be affixed to the copy of the bill of lading forwarded by the agent to the office and filed there. However, in every case a certificate signed or initialed by the carrier or his agent to the effect that the proper documentary stamps stating the value thereof, have been affixed to the copy retained by said carrier and cancelled, should be made on each and every unstamped copy of the bill of lading. It shall be the duty of every common carrier to keep a copy of each bill of lading issued by him in order that he may properly comply with the requirement herein. These retained copies must be preserved for one year from the date of issue in such a manner that they can be readily inspected by internal revenue officer. SECTION 122. Receipts of Delivery of Goods . Receipts given by a company to a shipper which serve as memorandum for delivery of goods to the express company, should be stamped in accordance with paragraph ( q ) of section 1449 of the Administrative Code. The law requires that for each shipment received for carriage or transportation, the common carrier shall issue to the shipper or consignor a stamped bill of lading, manifest, or other evidence of receipt and forwarding. ACIDTE SECTION 123. Invoices of Goods Sent Out by Merchants . There is no documentary stamp tax imposed on such invoices; but if an invoice takes the place of a bill of lading, such document then becomes subject to the documentary stamp tax under paragraph ( q ) or ( r ) of section 1449 of Act No. 2711. SECTION 124. Bills of Lading for Exported Alcoholic and Tobacco Products. There is nothing in the law showing any intent on the part of the legislature to exempt bills of lading for exported alcoholic and tobacco products from the documentary stamp tax provided in this paragraph. It will be noted, however, that only one stamp is required on each set of such bills of lading. Such stamp should be affixed in such case to the copy retained by the carrier or his agent, and no stamp is required on any of the copies, but a certificate to the effect that the proper documentary stamps stating the value thereof have been affixed to the copy retained by the carrier or his agent, should be made on each and every unstamped copy. SECTION 125. Bills of Lading (Through). Through bills of lading issued for merchandise to foreign ports for transhipment as well as local bills of lading for conveyancing goods from ports in the Philippine Islands to any foreign port, are each subject to the documentary stamp tax in this paragraph. SECTION 126. Unused or Cancelled Bills of Lading . No refund can be allowed on unused or cancelled bills of lading. SECTION 127. "Chits", memorandum slips, and other papers not in the usual commercial form of bills of lading, when used by common carriers in the transportation of merchandise or goods for the collection of fees therefor are considered as bills of lading, and the original thereof issued or used should bear the documentary stamp as provided by paragraph ( q ) or ( r ) of section 1449 of the Administrative Code. SECTION 128. Negotiation of Bills of Lading. No documentary tax is due on the indorsement or assignment or other negotiation of bills of lading for the reason that neither subsection ( q ) nor subsection ( z ) of section 1449 imposes such tax. BILLS OF LADING DOMESTIC On each set of bills of lading or receipts (except charter party) for goods, merchandise, or effects of greater value than five pesos shipped from one port or place in the Philippine Islands to another port or place in said Islands, four centavos. (Section 1449 ( r ).) SECTION 129. "Bill of lading", Defined. ( See Sec 120 of these Regulations.) SECTION 130. Basis of the Tax. ( See Sec. 121 of these Regulations.) SECTION 131. Affixture of Stamps. Documentary stamps under the provisions of this paragraph shall be affixed to the copy of the bill of lading which is retained by the carrier, but a notation signed by a responsible person shall be entered on the copies of such bill of lading not bearing documentary stamps to the effect that the documentary stamps of the proper amount have been duly affixed to the copy retained by the carrier. CHATEa SECTION 132. Sections 122, 123, 126, 127 and 128 of these Regulations are also applicable to cases under this subsection ( r ). PASSAGE TICKETS On each passage ticket, whether a single fare or return ticket, or any receipt for money paid for the passage of a person on any vessel other than on a vessel belonging to the Insular Government or the Government of the United States from any port in the Philippine Islands to a port in the United States or to any foreign port: (1) If said passage costs not more than sixty pesos, one peso and fifty centavos. (2) If said passage costs more than sixty pesos and not more than one hundred and twenty pesos, two pesos and fifty centavos. (3) If said passage costs more than one hundred and twenty pesos and not more than two hundred and fifty pesos, three pesos and fifty centavos. (4) If said passage costs more than two hundred and fifty pesos, five pesos. (Section 1449 ( s ), Act No. 2711, as amended by section 1, Act No. 3047.) SECTION 133. Basis of the Tax . It is to be noted from the above provisions of section 1449 ( s ) of the Administrative Code, as amended by section 1 of Act No. 3047 that the law now bases the tax on individual fares , so that if several fares are represented by a single passage ticket, so many taxes are due. SECTION 134. Tickets of Employees of the Government of the Philippine Islands or Employees of the Military Departments of the United States in the Philippine Islands. Steamship tickets of employees of the Civil Government or of the military departments of the United States who are returning from the Philippine Islands to the United States, wholly at the expense of the Government, are exempt from the documentary stamp tax provided by this paragraph, provided the ticket is purchased by the Government. HSDIaC This ruling is applicable only in cases where the official request for transportation, signed by the head of the proper bureau or department, specifically states that the employee in whose behalf transportation is requested is travelling at the expense of the Government. SECTION 135. Tickets Issued to Officers or Employees of the United States or Philippine Government. Steamship tickets issued to officers and employees of the Government of the United States or of the Philippine Islands or of any of their branches, who are travelling on official business and under orders of such Governments or branches thereof are not subject to tax under this subsection. SECTION 136. Steamship Passage Tickets for Transportation to Foreign Ports . If a steamship passage ticket were issued within the Philippine Islands for transportation between two foreign ports only, the law would require no documentary stamp on same. Where, however, a person desires to secure transportation from a port in the Philippine Islands to Europe the fact that such transportation is furnished him in segments clearly cannot be allowed to affect the documentary stamp tax which is due on a through ticket from the Philippines to Europe. The amount of the tax on such series of fragmentary tickets is not ascertained by taking each of them separately, but by regarding the whole series as one ticket. If, in addition to the regular series of fragmentary tickets mentioned above a separate ticket issued by another company is furnished to the passenger, such separate ticket is subject to the stamp tax in addition to that required on the regular series. SECTION 137. Passage Tickets Issued in the Philippine Islands Reading from a Foreign Port. Passage tickets issued in this country reading from a foreign port are exempt from the documentary stamp tax, provided they serve to entitle their holders to passage from such foreign port only, so that if they also include passage from this country to that port, the tax will properly accrue. If the passage tickets are issued by a company from the Philippine Islands to a foreign port, same being a portion of a through passage to another foreign port issued by another steamship company in the Philippine Islands drawing order in the former company for the local passage, the stamp shall be affixed to that ticket issued by the other steamship company and the tax is to based on the entire passage. However, a note should be put on the ticket issued by the former company to the effect that said ticket is part of another issued by such company on which the requisite documentary stamps had been affixed. SECTION 138. Affixture of Stamps. The stamps should be affixed to the stubs of each ticket issued or to the duplicate or copy thereof retained or filed at the office of the person natural or juridical, issuing same; and a note signed or initialed by the person issuing said ticket or his authorized representative should be made on the original ticket given to the passenger to the effect that the proper documentary stamps stating the value thereof, have been affixed to the stubs, duplicate or copies of the ticket, as the case may be. PROXIES FOR VOTING On each proxy for voting at any election for officers of any incorporated company or association, except associations or corporations for religious, charitable, or literary purposes or to manage public cemeteries, twenty centavos. (Section 1449 ( t ).) ECaITc SECTION 139. Tax on Proxies Attaches to the Instrument. The stamp tax on proxies attaches to the instruments; i.e., only one tax is collectible on each document appointing a proxy, and is not measured by the number of grantors. SECTION 140. Directors of Corporations. Directors of a corporation are officers within the meaning of the clause imposing a tax on proxies for voting at the election for officers of an incorporated company. SECTION 141. Scope of Tax under this Subsection. The tax under this subsection is levied only on proxies for voting at any election of officers of any incorporated company or association, either stock or nonstock, and for no other purpose, so that proxies for the purpose of voting stock or for the transaction of other business of an incorporated association or company is not subject to this tax. POWERS OF ATTORNEY On each power of attorney to perform any act whatsoever, except acts connected with the collection of claims due from or accruing to the Government of the United States, the Government of the Philippine Islands, or the government of any province or municipality, twenty centavos. (Section 1449 ( u ).) SECTION 142. Exemptions under this Paragraph. Under the exception in this paragraph the following papers are exempt from the documentary stamp taxes provided in section 1449: Jurat on travelling expense vouchers of Government employees and officials. Provincial Forms Nos. 2 and 9. Vouchers for payment of rent of building used for Government purposes. Vouchers statements, or certificates made by creditors of the Government on bills presented for payment. Documents issued by any Government employee for money paid on account of taxes. Checks drawn by any Government official in his official capacity against government funds, either insular, provincial or municipal. cEDaTS SECTION 143. Tax on Power of Attorney, When Due. The tax on a power of attorney is due when the instrument is executed and delivered. Delivery includes depositing instrument in the mails. SECTION 144. Tax Attaches to the Instrument. The tax is imposed on the instrument itself, and is not measured by the number of persons joining therein. SECTION 145. Documents Not Taxable . The following documents although they purport to authorize acts to be done by one person for, and on behalf and in the stead of, another, are not taxed as powers of attorney: (1) Resolution of a board of directors authorizing an officer of the corporation to sell, etc., stock or bonds, not taxed as power of attorney; otherwise in case of person not an officer. Where a corporation, by resolution of its board of directors, has empowered an officer thereof to sell, assign, or transfer stock or bonds standing in the name of the corporation, or to perform any act in the name of the corporation, such authority is not taxable as power of attorney for the reason that it is necessary for a corporation to perform its corporate acts through one of its officers. If, however, a person other than an officer of the corporation acting in his official capacity is given this authority, the power of attorney so granted is subject to stamp tax. (2) Power of sale embodied in mortgage not taxable. A power of sale embodied in a mortgage, authorizing and empowering a mortgagee himself, upon default, to make public sale of the property affected and to convey the title to the purchaser at such sale free from all rights or equity of redemption, thus avoiding the necessity of resorting to the courts for foreclosure, is not taxable. (3) Powers of attorney contained in assignments of insurance policies. Powers of attorney contained in assignments, absolute or as collateral security, of insurance policies are not subject to tax. (4) Authority of secretary of a corporation to transfer stock on the books not taxable. An instrument authorizing the secretary to transfer stock on the books of a corporation is not taxable as a power of attorney, but an instrument appointing an attorney in fact to transfer stock on the books of a corporation is taxable. (5) Pro forma power of attorney to transfer bonds or stocks on books of corporation, printed on bond or stock certificate, not taxable. The pro forma power of attorney to transfer bonds or stocks on the books of a corporation, embodied in the assignment printed on the back of the bond or stock certificate, is not subject to tax. (6) A warrant of attorney in a judgment note or promissory note authorizing confession of judgment. The clause in a judgment note or a promissory note authorizing confession of judgment is not taxable as a power of attorney. acAIES (7) Warrant of attorney in a lease. A warrant of attorney embodied in a lease is not taxable. (8) Power of attorney authorizing vendee of shares of stock to transfer same. A power of attorney by which a person executing the instrument sells, assigns, and transfers shares of stock and appoints the vendee agent for the transfer is not subject to tax. SECTION 146. Revenue Stamp Required on Each Instrument Executed under General Power of Attorney Granted to Person Not an Officer of the Corporation. A general power of attorney granted by a board of directors to a person, other than an officer a corporation acting in his official capacity for the purpose of transacting business of the corporation, including making conveyances of land and acknowledging deeds, is considered specific authority for each such transaction, and a revenue stamp is required on each instrument executed under the power of attorney. SECTION 147. Powers of Attorney from Corporations to Resident Agents. Powers of attorney executed by corporations to resident agents authorizing the latter to accept service of process are taxable. SECTION 148. Power of Attorney to Sell or Transfer Government Bonds. A power of attorney to sell or transfer Government bonds is taxable. SECTION 149. Power of Attorney Mailed in the Philippine Islands to Points Abroad; Power of Attorney Mailed Abroad to Party in the Philippine Islands. A power of attorney, executed and mailed within the Philippine Islands to a foreign point is subject to tax, but a power of attorney executed in a foreign country and mailed to an agent in the Philippine Islands is not subject to tax. SECTION 150. Power of Attorney to Sell, etc., Shares of Capital Stock Taxable. A power of attorney to sell, assign, and transfer shares of capital stock is subject to tax unless it is given in connection with a deposit of the stock as security for a loan. SECTION 151. Power of Attorney Authorizing Deputy to Have Access to Safe. A power of attorney authorizing a deputy to have access only to a safe or safety deposit box is not subject to tax, but a power of attorney to have access and control over its contents is subject to tax. DSacAE LEASES OF REAL ESTATE On each lease, agreement, memorandum, or contract for the hire, use, or rent of any lands or tenements, or portions thereof: (1) If executed for not more than one year, twenty centavos. (2) If executed for more than one year, and not more than three years, fifty centavos. (3) If executed for a period of more than three years, one peso. (Section 1449 ( v ).) SECTION 152. Leases. The 20-centavo documentary stamp tax imposed by subsection ( o ) of section 1449 of the Administrative Code, need not to be paid when the certificate is in the nature of an acknowledgment to a power of attorney, lease, mortgage, or pledge, conveyance, or any other document made subject to a documentary stamp tax by the provisions of subsections ( u ), ( v ), ( w ), and ( x ) of said section. MORTGAGES OF REAL OR PERSONAL PROPERTIES On every mortgage or pledge of lands, estate, or property, real or personal, heritable or movable, whatsoever, where the same shall be made as a security for the payment of any definite and certain sum of money lent at the time or previously due and owing or forborne to be paid being payable, and on any conveyance of land, estate, or property whatsoever in trust or to be sold or otherwise converted into money, which shall be and intended only as security, either by express stipulation or otherwise: (1) When the amount for which the mortgage or deed of trust is given is not less than one thousand pesos nor more than three thousand pesos, fifty centavos. (2) On each three thousand pesos, or fractional part thereof, in excess of three thousand pesos, an additional tax of fifty centavos. EHaCTA (Section 1449 ( w ).) SECTION 153. Tax to be Paid on the Sum of Money Hypothecated. The tax should be paid on the sum of money hypothecated and not upon the value of the property pledged or mortgaged. However, if the pledge and mortgage cover but one transaction, that is, secure the same amount, only one tax will be due, as the documents would be considered together as but one instrument and the tax would be payable on the instrument which is subject to the higher tax. SECTION 154. Deed of Trust in the Nature of a Mortgage. If an instrument purporting to be a contract of pledge executed by a company in favor of a bank, conveys certain bonds and shares of stock to the said bank as security for a credit, and confers upon the said bank power to sell or dispose of the same in case of failure on the part of the company, it is a deed of trust in the nature of a mortgage falling under subsection ( w ) of section 1449. SECTION 155. "Contrato de Prestamo y Prenda". Such document is a combined promissory note and mortgage and should bear the higher documentary stamp tax of the two to which it is subject. SECTION 156. Trust receipts or pledges of personal property given by firms to banks for the purpose of securing a loan will be considered subject to this tax as mortgages. SECTION 157. Bond Secured by a Mortgage. ( See Sec. 5 of these Regulations.) CONVEYANCES OF REAL ESTATE On all conveyances, deeds, instruments, or writings, other than grants, patents, or original certificates of adjudication issued by the Government, whereby any lands, tenements, or other realty sold shall be granted, assigned, transferred, or otherwise conveyed to the purchaser or purchasers, or to any other person or persons designated by such purchaser or purchasers: (1) When the true consideration, or value received or contracted to be paid for such realty, after making proper allowance for any incumbrance, is more than two hundred pesos but not more than two thousand pesos, fifty centavos. CTHDcS (2) For each additional one thousand pesos, or fractional part thereof, of such true consideration or value, fifty centavos. When it appears that the amount of the documentary tax payable hereunder has been reduced by an incorrect statement of the consideration in any conveyance, deed, instrument, or writing subject to such tax, the Collector of Internal Revenue, provincial treasurer, or other revenue officer shall, from the assessment rolls or other reliable source of information, assess the property at its true market value and collect the proper tax thereon. (Section 1449 ( x ).) SECTION 158. Deeds to Property Donated to the Government. No documentary stamp taxes are required on such documents. SECTION 159. Deeds Without Statement of Money Consideration. The value of the land transferred will be determined and taxes collected accordingly, where no consideration is stated, or if it be understated. The documentary stamp tax is based on the value of the property described in the deed. SECTION 160. Quit-claim Deeds; Partition of an Undivided Interest in a Piece of Property by Means of Quit-claim Deeds. If one document is used in such transaction the stamp tax in this paragraph accrues thereon. And on each copy of the instrument signed, sealed, and delivered, the tax will also be due. The true consideration in cases of such transaction is as follows: If one conveys, for instance, an undivided one-half of the property to the other, the real consideration of such transaction would be but one half of the value of the whole property; so if the two convey, one to the other, the same rule would apply. The transaction of the partition of an undivided interest, where one heir quit-claims to another in consideration of an equal quit-claim the other way, is but one disposition of the property in question, and neither one by quit-claiming to the other, is conveying the whole property, nor is his deed therefor subject to a tax upon the whole value of the property, but in such transaction the correct tax would be one tax upon the whole value of the property. SECTION 161. Deeds of Donation. Deeds of donation which expressly show upon the face of the instrument that the transfer is gratuitous and where as a matter of fact there is no consideration, are not subject to this tax. TSIDEa SECTION 162. S ales of Real Estate. Sales of real estate with right of repurchase commonly known as "pacto de retro" are not mortgages but sales of real estate and when, in such cases, the real property sold is repurchased by virtue of the contract contained in the original deed such repurchase constitutes a purchase and sale and cannot be considered as a cancellation of a mortgage or lien. Deeds given by virtue of "resales" to the original vendor of real property previously sold by him with a right to repurchase are subject to the stamp tax provided by this paragraph. SECTION 163. Contract for Sale of Land. If contract for the sale of land vests title on the land and improvements thereon, it would be subject to taxation as a conveyance. If it does not vest title but contains only certain provisions for the giving of a deed in the future upon compliance with conditions precedent, it is not subject to tax. SECTION 164. Deed of Real Estate Executed Abroad. A deed of real estate executed in the United States or any foreign country by the grantor and forwarded to the Philippine Islands for recording purposes is subject to the documentary stamp tax. TADcCS SECTION 165. Deed Executed by Sheriff, etc. Deeds of final sale, executed by the sheriff after the period of one year of legal redemption had expired in accordance with the Code of Civil Procedure, are subject to the documentary stamp tax. SECTION 166. Public Auction Sales. Deeds of sale at public auction of mortgaged real property, made by the sheriff pursuant to an order of foreclosure of mortgage, in favor of the purchaser or purchasers are subject to the documentary stamp tax. SECTION 167. Deed and Mortgage for the Same Piece of Property. This is not a case where encumbered property is sold and in which the amount of the incumbrance can be deducted from the consideration on account of the provisions of paragraph ( x ) of this section for the reason that the deed is necessary to vest the title in the party executing the mortgage and until such deed is executed no such mortgage can be made. There is nothing in paragraph ( x ) to indicate that the consideration must be a cash consideration. Both the deed and the mortgage are subject to tax. SECTION 168. Deeds Executed by Government Officials. The tax imposed by this paragraph does not accrue on any deed executed by a Government official for the purpose of conveying public land of any kind. SECTION 169. Actual Value at Time of Conveyance the Measure of the Tax. Where the consideration for a conveyance of lands, tenements, or other real property, is left open, to be fixed by future contingencies, the actual value at the time of conveyance is the measure of the tax upon the deed, instrument, or writing whereby the conveyance is made. SECTION 170. Tax, How Computed. In calculating the amount of stamps which must be affixed to a deed of conveyance, the tax is computed upon the full consideration for the transfer less all encumbrances which rest on the property before the sale and which are not removed by the sale. Encumbrances placed on the property in connection with and as a result of the sale or transfer, as well as notes for deferred payments, can not be deducted in determining the amount upon which the tax is calculated. SECTION 171. Tax on Deed Executed by Sheriff, Referee, or Commissioner, How Computed. The stamp tax on a deed of real property executed by a sheriff, referee, or commissioner to a mortgagee who bids in the property at foreclosure sale to satisfy a mortgage lien, should be computed upon the amount bid for the property plus the costs, if paid by the purchaser. SECTION 172. Deeds Conveying Property Sold under Foreclosure or Execution; Tax, How Paid. Deeds executed by sheriffs, clerks of court, etc., to cover transfers of property sold under a foreclosure or execution are subject to tax. The grantee or vendee may be required to pay the tax or the cost of revenue stamps may be included in the expenses of foreclosure sale. aSTECI SECTION 173. Deeds on Exchange of Properties. In the case of an exchange of two properties, the deeds transferring title to each are subject to tax, which should in each case be computed on the basis of the actual value of the interest or property conveyed, the amount of any preexisting lien or encumbrance which is not removed by the sale being deductible. SECTION 174. Deeds Conveying Mines. Deeds conveying mines are taxable. SECTION 175. Conveyance of Land in Consideration of Maintenance. A conveyance of land in consideration of life maintenance is taxable, the tax to be measured by the value of the property or interest conveyed. SECTION 176. Deeds of Building and Loan Associations. Deeds of building and loan associations conveying realty are taxable. SECTION 177. Stock in Corporation a Valuable Consideration. Stock in a corporation is a valuable consideration for the transfer of real property. SECTION 178. Options and Contracts for Real Estate. No tax is imposed upon an option for the purchase of real property or upon a contract for the sale of real estate. SECTION 179. Deeds of Release and Deeds of Trust. Deeds of release and deeds of trust are exempt from tax under the provisions of this law. SECTION 180. Deeds to Burial Sites. Deeds to burial sites which do not convey title to land, but only a right to sepulture, to erect monuments, etc., are not subject to stamp tax. SECTION 181. Deed to Trustee for Benefit of Creditor. A deed executed by a debtor covering an assignment of property to a trustee to be held for the benefit of a creditor is not subject to tax. When, however, the trustee sells or conveys such property either to the creditor or any other person, the deed executed by him is taxable. IcHSCT SECTION 182. Deeds from Agent to Principal. Deeds from an agent to his principal conveying real estate purchased for and with funds of the principal are not taxable. SECTION 183. Reconveyances of Partnership Property by Receivers. Conveyances of property of a copartnership, in the hands of receivers, back to the owners after administration of the estate are not taxable. SECTION 184. Partition Deeds. Partition deeds are not subject to tax unless a consideration passes between the parties by reason of one or more of them taking under the division a share of real estate of greater value than his undivided interest, in which event stamp tax attaches to the deeds conveying such greater shares, calculated upon the value of such consideration. SECTION 185. Conveyances without Consideration. Conveyances of realty, not in connection with a sale, to trustees or other persons without consideration are not taxable. SECTION 186. Contracts for Sale of Real Property. Contracts for the sale of real property are not taxable unless they vest title. SECTION 187. Conveyance by Coowners in Consideration of Capital Stock. A conveyance of real estate by coowners to a corporation organized for convenience in handling the property, made in consideration of the issue to them of the corporation's capital stock, is subject to tax. SECTION 188. Deeds by Executor. Deeds by an executor to devisees, conveying specific parcels of real estate, devised to them in common, are not subject to tax unless a consideration passes between the devisees by reason of some of them taking a greater share in the real estate than that to which they are entitled under the will, in which event tax attaches to the deeds conveying such greater shares, and is calculated upon the amount of value of such consideration. SECTION 189. Conveyances by Corporation to Owner of All the Capital. A conveyance of real estate by a corporation without valuable consideration to an owner of all its capital stock in consequence of its dissolution is not subject to tax. ACIESH SECTION 190. Conveyance by Mortgagor to Mortgagee. A conveyance by defaulting mortgagor to mortgagee in consideration of the cancellation of mortgage debt is subject to tax calculated on the amount of the mortgage debt plus unpaid accrued interest. SECTION 191. Conveyances to Trustee, or from Trustee to Cestui Que Trust, Without Consideration. Conveyances to a trustee without valuable consideration or from a trustee to a cestui que trust without valuable consideration are not subject to tax SECTION 192. Deed from One Corporation to Another Owning Capital Stock of Former in Consideration of Payment of Debts. A deed from a corporation, the entire capital stock of which is owned by another corporation, conveying real estate to the latter in consideration of the payment by the grantee of all obligations of the grantor is subject to tax. SECTION 193. Judgment or Decree of Court Transferring Title to Real Estate. Judgment or decree of a court operating to transfer title to real estate is not taxable as a conveyance. THcEaS SECTION 194. Taxes and Assessments, When Deductible. Taxes and assessments which have become a lien on real estate by operation of statute and which are not paid at time of sale are deductible from the consideration in computing the stamp tax. SECTION 195. Conveyance by Corporation to an Officer Through Third Party. Where an officer of a corporation purchases real estate from the corporation, conveyance being first made to a third party and as part of the same transaction, the property is conveyed by the third party to the officer, the conveyance to the third party is subject to tax, while the conveyance from the third party is not subject to tax. CHARTER PARTIES On every charter party, contract, or agreement for the charter of any ship, vessel, or steamer, or any letter or memorandum or other writing between the captain, master, or owner, or other person acting as agent of any ship, vessel, or steamer and any other person or persons for or relating to the charter of any such ship, vessel, or steamer, and on any renewal or transfer of such charter, contract, agreement, letter or memorandum: (1) If the registered gross tonnage of the ship, vessel or steamer is not more than three hundred tons, and the duration of the charter or contract is not over six months, six pesos; and for each month or fraction of a month in excess of six months, an additional tax of one peso shall be paid. (2) If the registered gross tonnage is more than three hundred tons but not more than six hundred tons, and the duration of the charter or contract is not more than six months, twelve pesos; and for each month or fraction of a month in excess of six months, an additional tax of two pesos shall be paid. DcaCSE (3) If the registered gross tonnage is more than six hundred tons and the duration of the charter or contract is not more than six months, twenty-four pesos; and for each month or fraction of a month in excess of six months, an additional tax of four pesos shall be paid. (Section 1449 (y) , as amended by section 1, Act No. 3047.) SECTION 196. Basis of the Tax. Under the above provisions of section 1449 (y) of the Administrative Code, as amended by section 1 of Act No. 3047, the tax is now based not only upon registered gross tonnage of the ship, vessel, or steamer chartered but also upon the duration of the charter. SECTION 197. Original of Document to Bear Stamp. All of the papers relating to the chartering of a vessel constitute one document, and such charter parties are, under the Commercial Code, required to be made in duplicate. The original only of the document is required to bear the stamp tax, but the duplicate copy should have noted thereon: "original duly stamped". SECTION 198. Charter Parties Made in the Philippine Islands. Every charter party made in the Philippine Islands is subject to the documentary stamp tax provided by this paragraph, whether the vessel chartered is a domestic or foreign one and whether such vessel is in Philippine waters or elsewhere. TRANSFERS AND RENEWALS OF CONTRACTS Upon each and every assignment or transfer of any mortgage, lease, or policy of insurance, or the renewal or continuance of any agreement, contract or charter by altering or otherwise, a stamp tax shall be levied, collected, and paid at the same rate as that imposed on the original instrument. (Section 1449 ( z ).) SECTION 199. Insurance Policy; Assignment or Transfer. Stamps upon the assignment or transfer of any mortgage, lease or policy of insurance, shall be the same as that required upon the original instrument. However, if the assignment or transfer is in the nature of a pledge of the insurance policy to secure a loan, the above ruling will not apply. SECTION 200. Policy Loan Agreement. Policy loan agreements which combine the nature of two documents, viz. , promissory note and assignment or transfer of the insurance policy, are subject to the tax on assignment or transfer of insurance policies at the rate of 10 centavos on each P200, or fractional part thereof, of the amount insured by the policy. SDTcAH SECTION 201. Assignment of Securities. An assignment of securities by an insurance company in favor of the Government of the Philippine Islands, made in compliance with the provisions of section 178 of Act No. 2427, is subject to the documentary stamp tax under section 1449 (z) of the Administrative Code. This ruling is made on the ground that the act performed serves interest other than those required to carry on the Government machinery. EXEMPTIONS The following instruments, documents and papers shall be exempt from the documentary stamp tax: (a) Bonds, debentures and certificates of indebtedness issued by the Insular Government or any provincial or municipal government. (b) Checks, drafts, warrants, and bills of exchange issued in payment of any debt, obligation, or liability, or in fulfillment of any contract of the Government of the United States, or the Insular Government, or of a provincial or municipal government. (c) Policies of insurance or annuities made or granted by a fraternal or beneficiary society, order, association, or cooperative company, operated on the lodge system or local cooperation plan, and organized and conducted solely by the members thereof for the exclusive benefit of its members and not for profit. (d) Certificates of oaths administered to any Government official, in his official capacity, or of acknowledgment by any Government official in the performance of his official duties; written appearances in any court by any Government official, in his official capacity; certificates of the administration of oaths to any person as to the authenticity of any paper required to be filed in court by any person or party thereto, whether the proceedings be civil or criminal; papers and documents filed in courts for the military, naval, insular, provincial, or municipal governments, whether civil or criminal; affidavits of poor persons for the purpose of proving poverty; statements and other compulsory information required of persons or corporations by rules and regulations of the military, naval, insular, provincial or municipal governments exclusively for statistical purposes and which are wholly for the use of the Bureau in which the same are filed, and not at the instance of, or for the use or benefit of, the person filing the same; certified copies and other certificates placed upon documents, instruments, and papers for the military, naval, insular, provincial, or municipal governments, made at the instance and for the sole use of some other branch of the military, naval, insular, provincial, or municipal governments; and certificates of the assessed value of lands, not exceeding two hundred pesos in value assessed, furnished by provincial or municipal treasurers to applicants for registration of title to land. When any bond, note or other obligation is secured by a mortgage, pledge, deed of trust, or by the assignment or transfer of any documentary security, one tax only shall be collected upon such papers, such tax to be at the highest rate imposed on such mortgage, bond, note, obligation or other document as the case may be. (Section 1450, Act No. 2711.) STIEHc SECTION 202. Exemptions under This Section. Under the provisions of section 1450 of the Administrative Code, the following papers are also exempt from the documentary stamp taxes: (a) Certified copies of documents filed in any office of the Government, when furnished to officers of the Federal or Insular Governments for official purposes. (b) Tax deeds and certificates of acknowledgment thereon. (c) Deeds to property donated to the Government. (d) Bonds for the appearance of defendants; and affidavits of bondsmen as to their solvency filed in criminal cases. (e) Certificates to oaths administered to sureties on bond of shipper of forest products required by regulations of the Bureau of Internal Revenue. (f) Bank reports required under section 1501 of the Administrative Code. (g) Certificates of ownership and transfer of cattle. (h) Enlistment papers of soldiers of the Philippine Constabulary. (i) Leases, contracts, and certificates of sale affecting Government "friar lands" and assignments of same so long as the land remains the property of the Government. (j) Affidavits of transfer of property, Provincial Form (9-a) , are not deeds but are forms required solely for the use and benefit of the Government for statistical purposes and are therefore exempt from documentary stamp taxes. EHSTDA (k) Certificates of origin issued by the Bureau of Customs (Customs Form 471). (l) Ordinary bills of sale of personal property. (m) Bill of sale for a steamship. A bill of sale for a steamship is not subject to the documentary stamp tax unless there is incorporated and described therein, either written or printed, a matter or thing which would cause the contract or a part thereof to become a document, instrument, or paper upon which a tax is specifically imposed, such as carrying with it a specific promise to pay, etc., in which case the bill of sale would be subject to such documentary stamp tax as is required upon the matter incorporated in and made a part of the bill of sale, that is, the specific document of which this bill of sale partakes. (n) Certificates of acknowledgments on instruments. No documentary stamps are required on certificates of acknowledgments to deeds, leases, powers of attorney, mortgages, or any documents taxed under paragraphs (t) , (u) , (v) , (w) , and (x) of section 1449 of the Revised Administrative Code, when such certificates are a necessary part of the instrument, but one documentary stamp tax will be collected on the instrument. ADMINISTRATIVE PROVISIONS SECTION 203. Manner of Payment of Stamp Tax. The documentary stamp tax imposed in section 1449 of the Revised Administrative Code, as amended by Act No. 3047, shall be paid under administrative Schedule J by the purchase and affixture of documentary stamps of the proper value to the document or instrument taxed or to such other paper as may be indicated by law 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 the same, said stamps should be adhered to the stubs or to the duplicates thereof, and that a note initialed by a responsible person on the face of such documents be made as follows: "Documentary stamps to the value of P________ have been affixed on the stub or to the duplicate (as the case may be)". SECTION 204. Cancellation of Documentary Stamps. The cancellation of documentary stamps affixed to taxable documents should be accomplished by writing or stamping the date across the face of the stamp itself and part on the paper to which it is attached. No manner of cancelling documentary stamps other than that provided for in section 1451 of the Administrative Code will be considered sufficient, and noncompliance with the provisions of that section will subject the offender to prosecution under section 2721 of the same Code. Both the person issuing and the one accepting any document to which the law requires that documentary stamps be affixed are liable for failure to affix and properly cancel such stamps. aDTSHc SECTION 205. Manner of Payment of Fines Imposed under Section 2721 of the Administrative Code, as Amended by Section 16 of Act No. 2835. All fines imposed under the provisions of section 2721 of the Administrative Code, as amended by section 16 of Act No. 2835, shall be paid by the purchase and affixture of stamps to the document or documents involved in the case: Provided, That if such documents are not available, the fine may be paid by the affixture and cancellation of stamps to a blank sheet of paper. No special report of collections of fines for violations of this section is required. All offers of compromise made for violation of law concerning the documentary stamp tax shall be deposited and accounted for by the purchase and affixture of documentary stamps to the back of the original signed admission of guilt, B.I.R. Form No. 418, except the stamp covering the tax which should be affixed to the document and properly cancelled. SECTION 206. Denominations of Documentary Stamps. Documentary stamps, in sheets, will be issued in denominations of 100, 50, 20, 10, 3, and 1 pesos and 50, 20, 10, 4, and 2 centavos, and will be furnished upon requisition to provincial treasurers who shall keep their deputies supplied with same. SECTION 207. Sales of Documentary Stamps; No Special Record Required. Deputy provincial treasurers shall sell documentary stamps to any person who applies for same. No special record of sale is required to be kept. SECTION 208. Issue of Documentary Stamps to Bonded Officials. In cases where it is necessary to accommodate the public, provincial treasurers may issue to bonded officials documentary stamps on memorandum receipt. In order to transfer the responsibility for the value of such stamps from the accountable officer to the bonded officials receiving them, the designation of such officials must be changed by the addition of: Agent in charge of the sale of internal revenue stamps. SECTION 209. Duties of Notaries Public and Other Officers Authorized to Administer Oaths. Section 2 of Act No. 2835 provides that "no notary public or other officer authorized to administer oaths shall add his jurat to the certificate on documents subject to the documentary stamp tax unless the proper documentary stamps are affixed thereto and cancelled". IDaCcS SECTION 210. Duplicates of Documents Which are Subject to Tax. The duplicate of a document would only be subject to the stamp tax where the same has been substituted and used in place of the original, and the original itself can not be reached by taxation. The documentary stamp tax provided for in section 1449 of the Administrative Code can only be imposed once with respect to each of the transactions enumerated in said section, so that even if the instrument embodying such transaction is executed in duplicate, only one of the copies need bear the required documentary stamp, and the copy to which the stamp is affixed shall be considered as the original. SECTION 211. Effective Date. These Regulations shall take effect upon their promulgation in the Official Gazette. (SGD.) MIGUEL UNSON Acting Secretary of Finance APPENDIX SCHEDULE OF DOCUMENTARY STAMP TAXES Schedule of documentary stamp taxes. The following is a schedule of documentary stamp taxes imposed by the Internal Revenue Law: (1) Agreement to sell shares or certificates of stock. On all agreements to sell shares or certificates of stock in any association, company or corporation, on each P200, or fractional part thereof, of the par value of such shares or stocks (Section 1449 ( c ), A. C.) P0.04 (2) Annuities. On all policies of annuities, or other instruments by whatever name the same shall be called, whereby an annuity may be made, transferred or redeemed, on each P200, or fractional part thereof, of the capital of the annuity, or should this be unknown, then on each P200 or fractional part thereof, of thirty-three and one-third times the annual income (Section 1449 ( m ), A. C.) .10 (3) Bills of exchange, inland (between points in the Philippine Islands), drawing interest, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( g ), A. C.) .02 (4) Bills of exchange, foreign (incoming). Upon any acceptance or payment upon acceptance of any bill of exchange drawn in a foreign country, but payable in the Philippine Islands, on each P200, or fractional part thereof, of the face value expressed in Philippine currency (Section 1449 ( h ), A. C.) .02 (5) Bills of exchange, foreign (outgoing). Bills of exchange drawn in but payable out of the Philippine Islands, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( i ), A. C.) .04 EAHcCT (6) Bills of lading (domestic). On each set of bills of lading or receipts, except charter party, for any goods, merchandise or effects of greater value than P5 shipped from one port or place in the Philippine Islands to another port or place in said Islands (Section 1449 ( r ), A. C.) .04 (7) Bills of lading (export). On each set of bills of lading or receipts, except charter party, for any goods, merchandise, or effects of greater value than P5 to be exported from a port in the Philippine Islands to any foreign port (Section 1449 ( q ), A. C.) .10 (8) Bonds. Bonds issued by any association, company, or corporation, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( a ), A. C.) .20 (9) Bonds issued in a foreign country. On all bonds issued in any foreign country there shall be paid by the person here selling or transferring the same such tax as is required by law on similar instruments, issued or sold in the Philippine Islands. On each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( d ), A. C.) .20 (10) Bonds. Bonds conditioned for the performance of the duties of any office or position for the doing or not doing of anything therein specified, on each P4, or fractional part thereof, of the premium charged (Section 1449 ( l ), A. C.) .02 (11) Bonds (surety). On each bond for indemnifying any person or persons, firm, or corporation, who shall become bound or engaged as surety for the payment of any sum of money for the due execution or performance of the duties of any office or position or to account for money received by virtue thereof (Section 1449 ( n ), A. C.) P0.50 (12) Bonds. On all bonds of any description, except such as may be required in legal proceedings, or which are not otherwise provided for in section 1449 (Section 1449 ( n ), A. C.) .50 (13) Certificates of indebtedness. Certificates of indebtedness issued by any association, company, or corporation, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( a ), A. C.) .20 (14) Certificates of indebtedness issued in foreign country. On certificates of indebtedness issued in any foreign country there shall be paid by the person here selling or transferring the same, such tax as is required by law on similar instruments when issued, sold, or transferred in the Philippine Islands. On each P200, or fractional part thereof, of the face value of such document (Section 1449 ( d ), A. C.) .20 CaDEAT (15) Certificates of stock. On every original issue, whether on organization or reorganization, by any association, company, or corporation, on each P200, or fractional part thereof, of the face value of such document (Section 1449 ( b ), A. C.) .20 (16) Certificates of stock issued in a foreign country. On all certificates of stock issued in any foreign country, there shall be paid by the person here selling or transferring the same, such tax as is required by law on similar instruments when issued, sold, or transferred in the Philippine Islands. On each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( d ), A. C.) .20 (17) Certificates of profit. Certificates of profit showing interest in the property or accumulations of any association, company, or corporation, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( e ), A. C.) .02 (18) Certificates of deposit drawing interest. Certificates of deposit drawing interest, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( g ), A. C.) .02 (19) Certificates of deposit not drawing interest. Certificates of deposit not drawing interest and payable at sight or on demand, on each P200, or fractional part thereof (Section 1449 (f) , A. C.) .02 (20) Certificates of damage. Except as limited by law, on each certificate of damage issued by any customs officer, marine surveyor, or other person acting as such (Section 1449 ( o ), A. C.) P0.20 And on every certificate or document issued by any customs officer, marine surveyor, or other person acting as such (Section 1449 ( o ), A. C.) .20 (21) Certificates by notaries public. On each certificate issued by notaries public (Section 1449 ( o ), A. C.) .20 (22) Certificates of any description. Certificates of any description required by law, or by rules or regulations of a public office (Section 1449 ( o ), A. C.) .20 (23) Certificates for the purpose of giving information. Certificates for the purpose of giving information or establishing proof of a fact, and not otherwise specified by law (Section 1449 ( o ), A. C.) .20 (24) Certificates showing interest in the property or accumulations of any association, company, or corporation. On each P200, or fractional part thereof, of the face value of such document (Section 1449 ( e ), A. C.) .02 ISaTCD (25) Charter party (contract or agreement for the charter of any ship, vessel, or steamer). ( a ) If the registered gross tonnage of the ship, vessel, or steamer is not more than 300 tons, and the duration of charter or contract is not over six months 6.00 For each month or fraction of a month in excess of six months, an additional tax of P1 is added. ( b ) If the registered gross tonnage is more than 300 tons but not more than 600 tons, and the duration of the charter or contract is not more than six months 12.00 For each month or fraction of a month in excess of six months, an additional tax of P2 shall be added. ( c ) If the registered gross tonnage is more than 600 tons and the duration of the charter or contract is not more than six months 24.00 For each month or fraction of a month in excess of six months, an additional tax of P4 shall be paid (Section 1449 ( y ), A. C., as amended by Sec. 1 of Act No. 3047.) (26) Checks. On all bank checks. (Section 1449 (f) , A. C.) .02 (27) Contracts. On each contract for the hire, use, or rent of any lands or tenements, or portions thereof: ( a ) If executed for not more than one year .20 ( b ) If executed for more than one year, and not more than three years .50 ( c ) If executed for a period of more than three years (Section 1449 ( v ), A. C.) 1.00 (28) Contract or agreement for the charter of any ship, vessel, or steamer. ( a ) If the registered gross tonnage of the ship, vessel, or steamer is not more than 300 tons, and the duration of the charter or contract is not over six months P6.00 For each month or fraction of a month in excess of six months, an additional tax of P1 is added. HSacEI ( b ) If the registered gross tonnage is more than 300 tons but not more than 600 tons, and the duration of the charter or contract is not more than six months 12.00 For each month or fraction of a month in excess of six months, an additional tax of P2 shall be added. ( c ) If the registered gross tonnage is more than 600 tons and the duration of the charter or contract is not more than six months 24.00 For each month or fraction of a month in excess of six months, an additional tax of P4 shall be paid. (Section 1449 ( y ), A. C., as amended by section 1, Act No. 3047.) (29) Conveyance of land in trust or as security. On any conveyance of land, estate, or property whatsoever in trust: ( a ) When the amount for which the deed in trust is given is not less than P1,000 nor more than P3,000 .50 ( b ) And on each P3,000 or fractional part thereof in excess of P3,000 (Section 1449 ( w ), A. C.) .50 (30) Debentures. Debentures issued by any association, company, or corporation, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( a ), A. C.) .20 (31) Debentures issued in a foreign country. On all debentures issued in any foreign country there shall be paid by the person here selling or transferring the same, such tax as is required by law on similar instruments when issued, sold, or transferred in the Philippine Islands. On each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( d ), A. C.) .20 (32) Deeds and conveyances of real estate. On all conveyances, deeds, instruments, or writings whereby any lands, tenements, or other realty sold shall be granted, assigned, transferred, or otherwise conveyed to the purchaser or purchasers: CHcTIA ( a ) When the true consideration is more than P200, but not more than P2,000 .50 ( b ) And for each additional consideration of P1,000 or fractional part thereof (Section 1449 ( x ), A. C.) .50 (33) Drafts. Drafts not drawing interest, and payable at sight or on demand (Section 1449 (f) A. C.) .02 (34) Drafts. Drafts drawing interest, on each P200 or fractional part thereof (Section 1449 ( g ), A. C.) P0.02 (35) Evidences of the transfer or sale of shares or certificates of stock. On any evidence of the transfer or sale (assignment in blank, delivery, or by any paper or agreement or memorandum) of the shares or certificates of stock in any association, company, or corporation, on each P200, or fractional part thereof, of the face value of such stocks (Section 1449 ( c ), A. C., as amended by Act No. 3047 .04 (36) Foreign bonds, debentures, etc. On all bonds, debentures, certificates of stock or certificates of indebtedness issued in any foreign country there shall be paid by the person here selling or transferring the same, such tax as is required by law on similar instruments, when issued, sold, or transferred in the Philippine Islands. On each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( d ), A. C.) .20 (37) Guaranty obligations. On all obligations guaranteeing the validity or legality of any bonds or other obligations issued by any province, municipality, or other public body or organization, and on all obligations guaranteeing the title to any real estate or guaranteeing any mercantile credits which may be made or renewed by any such person, association, company or corporation, on each P4, or fractional part thereof, of the premium charged (Section 1449 ( l ), A. C.) .02 (38) Insurance policies, life. On each P200 or fractional part thereof of the amount insured by any such policy (Section 1449 (j) , A. C.) .10 (39) Insurance policy; assignment or transfer. Upon each and every assignment or transfer of any policy of insurance, the stamp tax shall be collected, levied, and paid at the same rate as that imposed on the original instrument. (Section 1449 ( z ), A. C.) (40) Insurance policies, property. On all policies of insurance or other instrument by whatever name the same may be called, by which insurance shall be made or renewed upon property of any description, including rents or profits, against peril by sea or inland waters, or by fire or lightning, on each P4, or fractional part thereof, of the amount of the premium charged (Section 1449 ( k ), A. C.) .02 IAEcCa (41) Insurance policies of the nature of indemnity. On all policies of insurance or bonds or obligations of the nature of indemnity for loss, damage, or liability made or renewed by any person, association, company, or corporation transacting the business of accident, fidelity, employer's liability, plate glass, steam boiler, burglar, elevator, automatic sprinkler, or other branch of insurance (except life, marine, inland, and fire insurance), on each P4, or fractional part thereof, of the premium charged (Section 1449 ( l ), A. C.) P0.02 (42) Leases. On each lease, agreement, memorandum, or contract for the hire, use, or rent of any lands or tenements, or portions thereof: ( a ) If executed for a period of time not more than one year .20 ( b ) If executed for a period of time more than one year but not more than three years .50 ( c ) If executed for a period of time more than three years (Section 1449 ( v ), A. C.) 1.00 (43) Letters of credit. Letters of credit drawn in but payable out of the Philippine Islands, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( i ), A. C.) .04 (44) Memoranda of sales of shares or certificates of stock. On all memoranda of sales of shares or certificates of stock in any association, company, or corporation, on each P200, or fractional part thereof, of the par value of such shares or stocks (Section 1449 ( c ), A. C.) .04 (45) Memoranda of deliveries of shares or certificates of stock. On all memoranda of deliveries of shares or certificates of stock in any association, company, or corporation, on each P200, or fractional part thereof, of the face value of such shares or stocks (Section 1449 ( c ) A. C.) .04 (46) Memoranda of the transfer of shares or certificates of stock. On all memoranda of the transfer of shares or certificates of stock in any association, company, or corporation, on each P200, or fractional part thereof, of the face value of such shares or stocks (Section 1449 ( c ), A. C.) .04 (47) Memoranda for the hire, use, or rent of any lands or tenements, or portions thereof. On each memoranda for the hire, use, or rent of any lands or tenements, or portions thereof: AIHTEa ( a ) If executed for not more than one year .20 ( b ) If executed for more than one year, and not more than three years .50 ( c ) If executed for a period of more than three years (Section 1449 ( v ), A. C.) 1.00 (48) Memorandum showing interest in the property or accumulations of any association, company, or corporation. On each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( e ), A. C.) .02 (49) Mortgages. On every mortgage or pledge of lands, estate, or property, real or personal, heritable, or movable: ( a ) When the amount for which the mortgage is given is not less than P1,000 nor more than P3,000 P0.50 ( b ) And on each P3,000 or fractional part thereof in excess of P3,000 (Section 1449 ( w ), A. C.) .50 (50) Order for the payment of money (domestic). Orders for the payment of money issued by any bank, trust company, or any person or persons, companies, or corporations at sight or on demand (Section 1449 (f) , A. C.) .02 (51) Order for the payment of money. Order for the payment of money drawn in a foreign country but payable in the Philippine Islands, on each P200, or fractional part thereof, of the face value of such document (Section 1449 ( h ), A. C.) .02 (52) Order for the payment of money (foreign). Order for the payment of money, including telegraphic orders, issued by express or steamship companies or by any person or persons, drawn in but payable out of the Philippine Islands, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( i ), A. C.) .04 (53) Passage tickets. On each passage ticket, whether a single fare or return ticket or any receipt for money paid for passage of a person on any vessel other than a vessel belonging to the Insular Government or the Government of the United States or to any foreign port: ( a ) If said passage costs not more than P60 1.50 ( b ) If passage costs more than P60 and not more than P120 2.50 ( c ) If passage costs more than P120 and not more than P250 3.50 ( d ) If passage costs more than P250 (Section 1449 ( s ), A. C., as amended by Act No. 3047.) 5.00 AcSCaI (54) Policies of annuities. On all policies of annuities, or other instruments by whatever name the same shall be called, whereby annuity may be made, transferred, or redeemed, on each P200, or fractional part thereof, of the capital of the annuity, or should this be unknown, then on each P200, or fractional part thereof, of thirty-three and one-third times the annual income (Section 1449 ( m ), A. C.) .10 (55) Power of attorney. On each power of attorney to perform any act whatsoever, except acts connected with the collection of claims due from or accruing to the Government of the United States, the Government of the Philippine Islands, or the Government of any province or municipality (Section 1449 ( u ), A. C.) .20 (56) Power of attorney (for voting). On each proxy for voting at any election for officers of any incorporated company or association, except associations or corporations for religious, charitable, or literary purposes or to manage public cemeteries (Section 1449 ( t ), A. C.) P0.20 (57) Promissory notes. On each P200 or fractional part thereof of the face value (and also on each renewal) (Section 1449 ( g ), A. C.) .02 (58) Proxy. On each proxy for voting at any election for officers of any incorporated company or association, except associations or corporations for religious, charitable, or literary purposes or to manage public cemeteries (Section 1449 ( t ), A. C.) .20 (59) Receipts for money. On any receipt for money paid for the passage of a person on any vessel other than a vessel belonging to the Insular Government or the Government of the United States from any port in the Philippine Islands to a port in the United States or to any foreign port: ( a ) If said passage costs not more than P60 1.50 ( b ) If said passage costs more than P60 and not more than P120 2.50 ( c ) If said passage costs more than P120 and not more P250 3.50 ( d ) If said passage costs more than P250 (Section 1449 ( s ), A. C., as amended by Act No. 3047) 5.00 (60) Recognizances. Recognizances conditioned for the performance of the duties of any office or position for the doing or not doing of anything therein specified, on each P4, or fractional part thereof, of the premium charged (Section 1449 ( l ), A. C.) .02 IEDaAc (61) Renewal of insurance, life. On all policies of insurance, or other instruments by whatever name the same may be called, whereby any insurance shall be made or renewed upon any life or lives, on each P200, or fractional part thereof, of the amount insured by such policy (Section 1449 (j) , A. C.) .10 (62) Renewal of insurance on property. On all policies of insurance or other instruments by whatever name the same may be called whereby any insurance shall be made or renewed upon property of any description, including rents or profits against peril by sea or on inland waters, or by fire or lightning, on each P4, or fractional part thereof, of the amount of premium charged (Section 1449 ( k ), A. C.) .02 (63) Renewal of insurance policies of bonds or obligations, etc. On all policies of insurance or bonds or obligations of the nature of indemnity for loss, damage, or liability renewed by any person, association, company, or corporation transacting the business of accident, fidelity, employer's liability, plate glass, steam boiler, burglar, elevator, automatic sprinkler, or other branch of insurance (except life, marine, inland, and fire insurance), on each P4, or fractional part thereof, of the premium charged (Section 1449 ( l ), A. C.) P0.02 (64) Sales of shares or certificates of stock. On all sales of shares or certificates of stock in any association, company, or corporation, on each P200 or fractional part thereof, of the par value of each stock (Section 1449 ( c ), A. C.) .04 (65) Shares or certificate of stock. On all sales, agreements to sell, or deliveries, or transfers of shares or certificates of stock in any association, company, or corporation, on each P200, or fractional part thereof, of the par value of such shares or stocks (Section 1449 ( c ), A. C.) .04 (66) Telegraphic order for the payment of money. Telegraphic orders for the payment of money issued by express or steamship companies or by any person or persons, drawn in but payable out of the Philippine Islands, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( i ), A. C.) .04 (67) Transfer of certificates. Transfer of certificates showing interest in the property or accumulations of any association, company, or corporation, on each P200, or fractional part thereof, of the face value of such documents (Section 1449 ( e ), A. C.) .02 (68) Transfer of any mortgage, lease, or policy of insurance. Upon the transfer of any mortgage, lease, or policy of insurance, a stamp tax shall be levied, collected, and paid at the same rate as that imposed on the original instrument (Section 1449 ( z ), A. C.). TAHIED (69) Undertakings. Undertakings conditioned for the performance of the duties of any office or position for the doing or not doing of anything therein specified, on each P4, or fractional part thereof, of the premium charged (Section 1449 ( l ), A. C.) .02 (70) Warehouse receipts. On each warehouse receipt for any goods, merchandise, or property of any kind held in storage in any public or private warehouse or yard for any other person than the owner of such warehouse or yard (Section 1449 ( p ), A. C.) .20 Footnotes 1. Promulgated September 16, 1924, XXII Off. Gaz., 112, page 2335.