B.
EXCISES TAXES
Q. What is meant by excise taxes?
Ans. Excise taxes are taxes imposed on certain goods or articles manufactured or produced in
the Philippines for domestic sale or consumption or for any other disposition and to things
imported [Sec. 128(C),Tax Code].
Q. What is the justification and purpose of excise taxes?
Ans. Justification and Purpose of Excise Taxes.- Excise taxes may be justified on the following
grounds:
(1) To curtail consumption of certain commodities, excessive or indiscriminate use of which
is considered harmful to the individual or community [i.e., taxes on alcoholic beverages and
tobacco products];
(2) To protect domestic industry the production of which face competition from similar
imported articles;
(3) To distribute the tax burden in proportion to the benefit derived from a particular
government service;
(4) To raise revenues.
Q. What are subject to excise taxes?
Ans. Excise Taxes.- The following excise taxes being provided by the Tax Code:
(1) Excise taxes on certain goods (Sec. 129, Tax Code).
(2) Excise Tax on alcoholic products (Sec. 128 (C),Tax Code).
(a) Distilled spirits (Sec. 141, Tax Code).
(b) Sparkling /still and fortified wines (Sec. 142, Tax Code).
(c) Fermented liquors (Sec. 143, Tax Code).
(3) Excise Tax on tobacco products-
(a) Tobacco products (Sec. 144, Tax Code).
(b) Cigars and cigarettes (Sec. 145, Tax Code).
(4) Excise tax on petroleum products-
(a) Manufactured oils Sec. 148, Tax Code)
(b) And other fuels-i.e., kerosene, diesel, fuel, liquefied petroleum gas, asphalt, bunker
oil,etc.Sec. 148(a) to (j), Tax Code;
(5) Excise tax on miscellaneous articles [Chapter VI];
(a) Automobiles -15% to 100% of the selling price depending upon engine
displacement.Sec. 149, Tax Code);
(b) Non-essential goods- 20% gross sales-i.e., jewelry, precious metals, perfumes, and
toilet waters, yachts and other vessels intended for pleasure or sports.Sec. 150, Tax Code;
(6) Excise tax on mineral products. To be discussed in the succeeding chapter of this text.
(7) Imputed cigarettes.
Q. What is the nature of excise taxes?
Ans. Excise taxes subject directly the product or goods to tax. They are therefore, taxes on
property.
Ans. . Excise taxes subject directly the product or goods to tax. (Medina v. City of Baguio, 91
SCRA 854). They are therefore, taxes on property.
Q. What is Revenue Memorandum Circular (RMC) No. 12-2004?
Ans. It is an issuance providing for the Revised Tax Rates on Alcohol and Tobacco Products
Introduced on or before December 31, 19991 and for those Alcohol and Tobacco Products
Covered by Rev,Memo Circular No. 22-2003 and 23-2003, Implementing Republic Act No. 9334,
otherwise known as an "Act Increasing the Excise tax Rates Imposed on Alcohol and Tobacco
Products, Amending for the Purpose Sections 131, 141, 142, 243, 44, 145 and 288 of the National
Internal Revenue Code of 1997, as amended.
ACCRUAL AND PAYMENT
Q. When shall excise taxes accrue?
Ans. Accrual.- Excise/specific taxes accrue and attach in any of the following cases:
(1) Generally, at the time of the removal of the articles;
(2) At the time of the removal from custody in cases of imported articles or goods;
(3) As to domestic products they accrue or attach as soon as they are produced or in case of
distilled spirits they accrue from their coming into existence.
Q. When shall excise tax be due and payable?
Ans. When Tax Due and Payable.- The observed rules depend on the nature of the covered
articles-
(1) Domestic Products -taxes on domestic products shall be paid immediately before removal
from the place of production. The excise tax on locally manufactured petroleum products shall be
paid within 15 days from date of removal from the place of production;
(2)Imported Articles-the taxes shall be paid before the release of such articles from the
custom house or by the person who is found in possession of articles which are exempt from
excise/specific tax other than those to whom the same is lawfully issued.
Q. Who pays excise taxes?
Ans. The following rules are observed in the Philippines concerning the persons to pay excise
taxes:
(1) On Domestic Articles-the excise taxes shall be paid by the manufacturer producer or
owner or even by one in possession of the articles subject to excise taxes Sec. 131A), Tax Code).
(2) On Imported Articles/goods-the excise taxes shall be paid by The owner or importer to
custom officer before the release of such articles from the customhouse (Sec. 127, Tax Code).
Q. Is prepayment of taxes a condition sine qua non before removal or release of the
taxable goods?
Ans. Exemption on Conditional Tax-Free Removal of Certain Articles.- Upon compliance
with certain conditions and requirements the following articles may be removed without
prepayment of taxes:
(1) Removal of wines and distilled spirits for treatment of tobacco leaf(Sec. 133, Tax Code).
(2) Exemption of domestic denatured alcohol (Sec. 134, Tax Code).
(3) Exemption of petroleum products sold to international carriers and export exempted per
agencies Sec. 135, Tax Code).
(4) Denaturation ,withdrawal and use of denatured alcohol (Sec. 136, Tax Code).
(5) Removal of spirits under bond for rectification.(Sec. 137, Tax Code).
(6) Removal of fermented liquors to bonded warehouse (Sec. 138, Tax Code).
(7) Removal of damaged liquors free of tax (Sec. 139, Tax Cod0e).
(8) Removal of tobacco products without prepayment of tax (Sec. 140, Tax Code)
Q. What are the units of measurements of taxable goods covered by excise/specific taxes?
Ans. The following physical units of measurement are used in fixing the rates of the
articles/goods/commodities subject to excise/specific taxes:
(1) Volume- used in distilled spirits, fermented liquors, manufactured oils and other fuels;
(2) Length- used in cinematographic films;
(3) Weight- used in manufactured tobacco products, fireworks, coal, coke, bunker fuel, oil
diesel fuel oil and saccharine;
(4) Number- used in cigars, cigarettes and matches.
(5) Price- the price at which the articles are sold at wholesale in the place of production or
through their sales agents to the public shall constitute the gross selling price and the basis of the
ad valorem tax.
REGULATING BUSINESS
Q. Relative to the enforcement of specific excise/ad valorem taxes, what are the powers
of the Commissioner?
Ans. Powers of the Commissioner/BIR.- The Bureau of Internal Revenue has the following
powers and functions related to the enforcement of specific/excise/ad valorem taxes:
(1) To supervise establishment where articles subject to such taxes are made or kept (Sec. 152,
Tax Code).
(2) To approve premises where business is to be conducted (Sec. 154, Tax Code).
(3) To assign internal revenue officers in establishment or places where articles subject to
excise taxes are produced/kept (Sec. 12, Tax Code).
(4) To conduct searches and seizures of taxable articles (Sec. 171, Tax Code)
(5) To detain packages containing taxable articles (Sec. 172, Tax Code.).
(6) To refund internal revenue stamps under certain cases.
Q. What are the various requirements to be complied with by the taxpayer in connection
with the excise/specific/ ad valorem taxes?
Ans. Requirements.- The requirements to be complied with by the taxpayers [i.e.,
manufacturers, importers] connected with excise/specific/ad valorem taxes are
(1) GENERAL BIR REQUIREMENTS- As exemplified by the following:
(a) To keep such records as required by the regulations recommended by the
Commissioner and approved by the Secretary of Finance (Sec. 153, Tax Code);
(b) To keep records of raw materials which are not only public documents but the
basis also for any assessment Sec. 153, Tax Code).
(c) To provide themselves with counting or metering devices to determine production
(Sec. 155,Tax Code)..
(d) To preserve invoices and stamps (Sec. 163, Tax Code).
(e) To provide labels and markings of packages subject to excise tax (Sec. 156, Tax
Code].
(f) To remove articles after payment of tax Sec. 157, Tax Code).
(g) To provide information relative to capacity, installation or removal of any
apparatus or mechanical contrivances (Sec. 164, Tax Code).
(h) To put up the required manufacturer's bonds (Sec. 160, Tax Code).
(2) IMPORTER'S REQUIREMENTS- In addition, importers are required:
(a) To put up importer's bonds conditioned for their faithful compliance with their
obligation as well as to answer for fines and penalties under the Tax Code (Sec. 160, Tax
Code).
(b) To store goods in internal revenue bonded warehouse (Sec. 156, Tax Code).
(3) EXPORTERS' REQUIREMENTS.- As additional requirements, exporters are likewise
required:
(a) To submit proof of exportation (Sec. 159, Tax Code).
(b) To give bond conditioned that the exportation is made in good faith (Sec. 159, Tax
Code). .
(4) ADDITIONAL REQUIREMENTS- the following requirements must be complied with
additionally:
(a) Records to be kept by wholesale dealers (Sec. 161, Tax Code). .
(b) Records to be kept by dealers in leaf tobacco Sec. 162. Tax Code). .
(c) Establishment of distillery warehouse (Sec. 165, Tax Code).
(d) Requirements governing rectification and compounding of liquors (Sec. 170, Tax
Code).
Q. What are the penal sanctions being meted in connection with the enforcement of the
excise tax?
Ans. To assure enforcement and/or compliance with the ex
(1) Fines;
(2) Imprisonment;
(3) Both fines and imprisonment;
(4) Forfeiture and confiscation.
Other Imposable penalties are:
(5) Deportation [if an alien];
(6) Perpetual disqualification to hold public office;
(7) Deprivation of the right of suffrage; and
(8) Revocation of business permit.
A. EXCISE TAX ON MINERAL PRODUCTS
Q. What is the concept of mining axes? Give the meaning of mining taxes?
Ans. Concept.- Mining taxes are taxes imposed on mineral lands and their development. They
are imposed on the privilege to explore, exploit and develop mining resources.
Q. State the nature of mining taxes.
Ans. Nature.- Mining taxes are excise taxes.
Q. Define the following terms: mineral, mineral products and quarry resources.
Ans. Defined.- As defined-
(1) Mineral- shall mean all naturally occurring inorganic substances stances [found in nature]
whether it be solid, liquid, gaseous or any intermediate state [Sec. 151(B) (2) Tax Code].
(2) Mineral Products- shall mean things produced and prepared in a marketable state by
simple treatment processes such as washing or drying, but without undergoing any chemical
change or process or manufacturing by the lessee, concessionaire or owner of mineral lands [Sec.
151 (B) (3), Tax Code].
(3) Quarry resources- shall mean any common stone or other common mineral substances as
the Director of the Bureau of Mines and Geo-Sciences may declare to be quarry resources such as,
but not restricted to marl, marble, granite, volcanic cinders, basalt, tuff and rock phosphate (Sec.
151, (B)(4); see also RA No. 6424).
Q. Classify mining taxes. What are the kinds of mining taxes?
Ans. Kinds of Mining Taxes.-Taxes and fees relating to mines are classified into: occupation
tax; rentals; and excise on mineral products.
Note: Only excise tax of mineral products being retained/ provided by the National Internal
Revenue Code (RA No. 8424)
Q. Discuss the tax rates of excise tax on mineral products.
Ans. Tax Rates.- These taxes are paid by the lessee of the mineral lands and they are payable
upon removal of the mineral products from locality where mined. The rates are:
(1) Coal and coke- P10.00 per metric ton (Sec. 151, Tax Code).
(2) Non-metallic and quarry resources- 2% of the actual market value of actual gross output
(Sec. 151(A(2), Tax Code].
(3) Metallic minerals-
(a) Copper -graduated -1% [Sec. 151,(A)(s\3) Tax Code)]
(b) Gold and chromite- 2% [Sec. 151(A) (2), Tax Code].
(c) Indigenous petroleum shall include locally extracted mineral oil hypocarbon,
gas, bitumen, crude asphalt, mineral as and other minerals.( Sec. 151(A)(3), Tax Code).
DOCUMENTARY STAMPS TAX
Q. State the governing laws on documentary stamp tax?
Ans. Governed by Title VII (Documentary Stamp Tax of the Tax Code of 1997 as:
(1) Amended by the provisions of Republic Act No. 9243 otherwise known as "Am Act
Rationalizing the Provisions on the Documentary Stamp Tax of the National Internal Revenue
Code of 1998, as Amended and for Other Purposes. which took effect last March 20,2004.
(2) As implemented by Revenue Memorandum Circular (RMC) No. 13-2004 dated
December 23m 2004.
Q. Give the meaning of documentary stamp tax. •
What is documentary stamp tax?
Ans. Meaning.- A documentary stamp tax is a tax imposed or affixed on documents,
instruments and papers evidencing the acceptance, assignment or sale of a right, property or
obligation.
Q. What is the nature of documentary stamp tax?
Ans. Nature.- It is an excise tax because it is imposed on the transactions other than on
documents; the law taxes the documents because of the transaction.
Q. Cite the purpose of documentary stamp tax?
Ans. Purpose. The purpose of the law imposing stamp taxes on documents, instruments,
and papers is to raise revenue and not to invalidate contracts or inflict penalties and courts should
give it a liberal construction (33 CS 315-316).
Q. Who pays the documentary stamp tax?
Ans. The one bound to pay the documentary stamp is the person making, signing, issuing,
accepting, or transferring the obligation, right or property (Sec. 173, Tax Code).
Q. What documents are subject to documentary stamp taxes?
Ans. Stamps Required.- The documents which stamps are required are the following:
(1) Stamp tax on documents, loan agreements, Instruments and papers (Sec. 173, Tax Code
as amended by Rep. Act No. 9243).;
(2) Stamp tax on original issue of shares of stock -P1.00 on each P200.00 Sec. 175, Tax Code
as amend by Sec. 3. RA No. 9243).
.(3) Stamp tax on sales, agreements to sell, memorandum of sales, and subsequent transfer of
shares of stocks- P0.75 on each P200 or fraction thereof (Sec. 176, Tax Code as amended by
Sec. 4, Ra No. 9243; RR No. 13-2004).
(4) Stamp tax on bonds, debentures, certificates of stock or indebtedness issued in foreign
countries-.P0.30 on each P200.00 Sec. 176; Tax Cod as renumbered by , Rep. Act. No. 9243;;see,
RR No. 13-2004);
(5) Stamp tax on certificates of profits and interest in property or accumulation (Sec. 177 Tax
code; as renumbered by RA No. 9243);
.(6) Stamp tax on bank checks drafts, certificates of deposit not bearing interest, and other
instruments(Sec. 178 Tax Code; as renumbered by RA No.9243;).
(7) Stamp tax on all debts instruments.- P1.00 on each P200.00 or fractional thereof (Sec.
180, Tax Code as amended by Sec. 6, RA NO. 9243; RRA No. 13-2004).
(8) Stamp tax on all bills of exchange or drafts- P0.30 on each P200.00.(Sec. 181, Tax Code
as renumbered by RA No. 9243);
(9) Stamp tax upon acceptance of bills of exchange and others -P0.30 on each P200.00 (Sec.
181, Tax Code ; ibid) policies -P0.50 on each P4.00. (2Sec. 185, Tax Code as renumbered by RA
No. 9243).
(10) Stamp tax on foreign bills of exchange and letters of credit- P0.30 on each P200.00 (Sec.
182, Tax Code, ibid).
(11) Stamp tax based for life insurance policies- P0.50 on each P200.00 or fraction thereof
(Sec. 183 as amended by RA No. 9243; Sec/ 7; RR No. 13-2004).
(12) Stamp tax on policies of insurance upon property -P0.50 on each P4.00 (Sec. 184, Tax
Code ibid).
(13) Stamp tax on fidelity bonds and other insurance (14) Stamp tax on policies of annuities
and pre-need plans- P0.50 on each P500.00 (Sec. 186 as amended by Sec. 8 RA No. 9243; RMC
No. 13-2004).
(15) Stamp tax on indemnity bonds- P0.30 on each P4.00,(Sec. 185, as renumbered, ibid).
(16) Stamp tax on certificates -P15.00 (Sec.. 188, Tax Code as renumbered, ibid).
(17) Stamp tax on warehouse receipts- P15.0026Sec. 189, ibid).
(18) Stamp tax on jai-alai, horse racing tickets, lotto or other authorized number games -P0.10
if it exceeds P1.00, P0.10 on every P1.00 (Sec. 190, Tax Code, ibid).
(19) Stamp tax on bill of landing or receipts- P10.00 if less than P100.0(Sec. 191, ibid).
(20) Stamp tax on proxies -P15.00 (Sec. 192, Tax Code ).
(21) Stamp tax on powers of attorney- P5.00. (Sec. 193, ibid).
(22) Stamp tax on leases and other hiring agreements - P3.00 for first P2, 000 and additional
P1.00 for every excess P1,000(Sec. 194, Tax Code).
(23) Stamp tax on mortgages, pledges and deeds of trust- P20.00 for less than P5,.000 and
any excess P10.00 for every P5,000.00 (Sec. 195, Tax Code; renumbered, ibid)_.
(24) Stamp on deeds of sale and conveyances of real property- for first P1,000.00,P15.00 and
any excess, P15.00 for each additional P1,000.00 (Sec. 196, Tax Code; renumbered, ibid)
(25) Stamp tax on charter parties and similar instruments- P1,000.00 (Sec. 197, Tax Code
renumbered, ibid).
(26) Stamp tax on assignment and renewal of certain instruments (Sec. 198, Tax Code;
renumbered, ibid).
Q. State the meaning and coverage of "debt instruments” as provided by Sec. 179 Tax
Code as amended by RA No. 9243 and as further implemented by Rev. Reg. No. 13-2004.
Ans. Debt instrument" shall mean instruments representing borrowing and lending transaction
including but not limited to:
(1) debentures;
(2) certificate of indebtedness;
(3) due bills;
(4) bonds;
(5) loan agreements, including those signed abroad wherein the object of the contract is located
or covered in the Philippines;
(6) instruments and securities issued by the government or any of its instrumentalities;
(7) deposit substitute debt instruments;
(8) certificates or other evidences of deposit that are drawing instrument significantly higher
than the regular saving deposit taking into consideration the size of the deposit and the risks
involved.
(9) certificates or other evidences of deposits that are drawing interest having a specific
maturity date;
(10) orders for payment of any sum of money otherwise than at sight or on demand.
(11) promissory notes, whether negotiable or non-negotiable, except bank notes issued for
circulation. ‘
Q. What are some of the basic rules documentary stamp tax on debt instruments?
Ans. These basic rules:
(1) The documentary stamp tax on all debt instruments shall be imposed only on every original
issue and the tax shall be based on the issue price thereof. Hence, sale of a debt instrument in the
secondary market will not be subject to documentary stamp tax.
(2) If the debt instrument has a term of less than one year, the documentary stamp tax due
shall be computed taking into consideration the number of days that the instrument is outstanding
as a fraction of 165 days. Thus, a promissory note in the mount of P100,000.00 is issued with a
term of 90 days from issue date. The documentary stamp tax due is P123,30 computed as follows;
P100,000.00/P200.00 500 X P1.00- P500.00 x 90/365P123.29 or P123.30
(3) If the debt instrument has a term of one year or longer, the documentary stamp tax shall
be computed based on the issue price of the debt instrument. Thus, a promissory note is issued a
price of P100,000.00 with a term of two years. The documentary stamp tax due is P500.00
computed as follows:
P100,000.00/P200.00 P500.00 x P1.00 P500.00
Q. Are there documents that are excepted from the documentary stamp tax?
Ans. Yes. Like
(1) The exempted documents provided by SEC. 199 of the Tax Code before its being amended
by Sec. 9 of Rep. Act No. 9243 and Rev. Reg. No. 13-2004.
The following documents are exempted from the documentary stam0p tax: policies of
insurance or annuities grated by fraternal or beneficiary society; certificate of oaths administered
to any government office; affidavit of poor persons proving poverty; information necessary for
statistical purposes; papers and documents filed in courts by or r the national and local
governments; certificates of the assessed value of the land not exceeding P200.00, applicants to
land registration.(Sec. 199, Tax Code).
(2) Those provided by the amended Sec. 199 of the Tax Code. Thus, as provided: "The
provisions of Section 173 to the contrary not withstanding, the following instruments, documents
and papers shall be exempt from the (documentary stamp tax (DST):
(a) 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 each member and not for profit.
(b) Certificates of oaths administered to any governmental official in his official
capacity or of acknowledgment by any government official in the performance of his
official duties written appearance in an courts by any government official in his official
capacity, certificates of the administration of oath 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 docu ments filed in courts by or for the
national, provincial , city or municipal govern ments; affidavits of poor persons for the
purpose of proving poverty; statements and other compulsory information required of
persons or corporations by sole use of some other branch of the national , provincial, city
or municipal govern ments, and certificates of the assessed value of lands, not exceeding
two hundred pesos (P200.00) in value assessed the rules and regulations of the national,
provincial, city or municipal governments exclusively for statistical purposes and which
are wholly for the use of the bureau or office in which they are filed and not at the instance
or for the use or benefit of the person fling them certified copies and other certificates
placed upon documents, instruments and papers for the national ,provincial, city or
municipal govern ments, made at the instance and for the furnished by the provincial,
city or municipal treasurer to applications for registration of title to land.
(c) Borrowing or lending of securities executed under the Securities Borrowing
agreement acceptable to the appropriate regulatory authority and which agreement is duly
registered and approved by the Bureau of Internal and Lending Program of a registered
exchange, or in accordance with the regulations prescribed by the appropriate regulatory
authority; Provided, how ever, That any borrowing or lending of securities agreement as
contemplated hereof shall be duly covered by a master securities borrowing and lending
agreement acceptable to the appropriate regulatory authority and which agreement is duly
registered and approved by the Bureau of Internal Revenue (BIR).
(d) Loan agreements or promissory notes, the aggregate of which does not exceed
two hundred fifty thousand pesos )P250,000.00) or any such amount as may be determined
by the Secretary of Finance, executed by an individual for his purchase on installment for
his personal use or that of his family and not for business or resale, barter or hire of a
house lot, motor vehicle, appliance or furniture; Provided, however, That the amount to
be set by the Secretary of Finance shall be in accordance with a relevant price index but
not to exceed ten percent (10%) of the current amount and shall remain in force at least
for three (3) years.
(e) Sale, barter or exchange of shares of stock listed and traded through the local
stock exchange for a period of five(5) years from affectivity of this Act.
(f) Assignment or transfer of any mortgage, lease or policy of insurance, or the
renewal or continuance of any agreement, contract, charter or any evidence of obligation
or indebtedness, if there is no change in the maturity date or remaining period of coverage
from that of the original instrument.
(g) Fixed income and other securities traded in the secondary market or through an
exchange.
(h) Derivatives, Provided, that for the purpose of this exemptions, repurchase
agreements or reverse repurchase agreements shall be treated similarly as derivatives.\
(i) Inter branch or interdepartmental advances within the same legal entity;
(j) All forbearances arising form sales or service contracts including credit card and
trade receivables Provided, that the exemption is limited to those executed by the seller or
service provided itself.
(k) Bank deposit accounts without a fixed term or maturity;
(l) All contracts, deeds, documents and transactions related to the conduct of business
of the Bangko Sentral ng Pilipinas.
(m) Transfer of property pursuant to Section 40(C)(2) of the National Internal Revenue
Code of 1997 as amended.
(n) Interbank call loans with maturity of not more than seven(7) days to cover
deficiency in reserves against deposit liabilities including those between or among banks
and quasi-banks.(Sec. 199 as amended by Sec. 9, RA No. 9248; see Sec. 9 RR No. 13-
204).
Q. When shall documentary stamp taxes be paid?
Ans. Payment.- The documentary stamp taxes shall be paid at the time the act was done or the
transaction being had. That is, the documentary stamps shall be affixed to the taxable document
at the time it is issued or executed. The tax may be paid either through purchase and actual
affixture or by imprinting the stamps through a documentary stamp metering machine. (39Sec.
200, Tax Code ).
Q. Where to affix documentary stamp?
Ans. The required stamps are to be affixed:
(1) As a rule, on the document or deed subject to such tax;
(2) On the books of the company;
(3) On the stub or duplicate in case of certificates of stocks or other securities;
(4) On the certificates or at times on the bill/memorandum.
Q. How to cancel documentary stamps?
Ans Cancellation of Stamps.- Cancellation is effected by writing, stamping or perforating the
date of cancellation across the face of each stamp; and if the date of cancellation is written or
stamped a visible hole must be punched out or perforated on the stamps.
Q. State the rule and effects when no stamps being affixed on documents that require
documentary stamps.
Ans. Effects.- Failure to affix stamps on a taxable document does not, however, invalidate the
document. The effects of the taxable document without stamps are:
(1) It cannot be recorded in the proper office;
(2) It cannot be admitted/use as evidence in court;
(3) Notary public or other officers to administer oath shall not add jurat or acknowledgment
until the document is properly stamped (Sec. 201, Tax Code). However, stamps not properly
affixed does not mean also failure to pay such tax; hence, the taxpayer is not required to pay anew
the value of those stamps wrongly affixed.
Q. When is the effectivity of Rep.Act No. 9243 and its implementing regulation- Rev.
Reg. No. 13-2004?
Ans. These regulations shall apply to all transitions made or to documents/instruments
executed and issued as of March 20, 2004, the date when RA No. 9243 took effect.