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RE: LETTER OF MR. OCTAVIO KALALO.

This case has been cited 7 times or more.

	GR No. 169103 2011-03-16	CIR v. MANILA BANKERS' LIFE INSURANCE CORPORATION LEONARDO-DE CASTRO, J.
Section 173. Stamp Taxes Upon Documents, Loan Agreements, Instruments and Papers. -- Upon documents, instruments, loan agreements and papers, and upon acceptances, assignments, sales and transfers of the obligation, right or property incident thereto, there shall be levied, collected and paid for, and in respect of the transaction so had or accomplished, the corresponding documentary stamp taxes prescribed in the following sections of this Title, by the person making, signing, issuing, accepting, or transferring the same wherever the document is made, signed, issued, accepted, or transferred when the obligation or right arises from Philippine sources or the property is situated in the Philippines, and the same time such act is done or transaction had: Provided, That whenever one party to the taxable document enjoys exemption from the tax herein imposed, the other party who is not exempt shall be the one directly liable for the tax. [34]
	GR No. 169103 2011-03-16	CIR v. MANILA BANKERS' LIFE INSURANCE CORPORATION LEONARDO-DE CASTRO, J.
Section 198. Stamp Tax on Assignments and Renewals of Certain Instruments. - Upon each and every 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 by altering or otherwise, there shall be levied, collected and paid a documentary stamp tax, at the same rate as that imposed on the original instrument.[44]
	GR NOS. 156637/162004 2005-12-14	PHILAM ASSET MANAGEMENT v. CIR PANGANIBAN, J.
On November 5, 1985, all prior amendments and those introduced by PD 1994[15] were codified[16] into the National Internal Revenue Code (NIRC) of 1985, as a result of which Section 86 was renumbered[17] as Section 79.[18]
	GR NOS. 134587 & 134588 2005-08-08	CIR v. BENGUET CORPORATION TINGA, J.
The transactions in question occurred during the period between 1988 and 1991. Under Sec. 99 of the National Internal Revenue Code (NIRC),[6] as amended by Executive Order (E.O.) No. 273 s. 1987, then in effect, any person who, in the course of trade or business, sells, barters or exchanges goods, renders services, or engages in similar transactions and any person who imports goods is liable for output VAT at rates of either 10% or 0% ("zero-rated") depending on the classification of the transaction under Sec. 100 of the NIRC. Persons registered under the VAT system[7] are allowed to recognize input VAT, or the VAT due from or paid by it in the course of its trade or business on importation of goods or local purchases of goods or service, including lease or use of properties, from a VAT-registered person.[8]
	GR Nos. 134587 & 134588 2005-07-08	CIR v. BENGUET CORPORATION TINGA, J.
The transactions in question occurred during the period between 1988 and 1991. Under Sec. 99 of the National Internal Revenue Code (NIRC),[6] as amended by Executive Order (E.O.) No. 273 s. 1987, then in effect, any person who, in the course of trade or business, sells, barters or exchanges goods, renders services, or engages in similar transactions and any person who imports goods is liable for output VAT at rates of either 10% or 0% ("zero-rated") depending on the classification of the transaction under Sec. 100 of the NIRC. Persons registered under the VAT system[7] are allowed to recognize input VAT, or the VAT due from or paid by it in the course of its trade or business on importation of goods or local purchases of goods or service, including lease or use of properties, from a VAT-registered person.[8]