RMC No. 48-2011: Circularizes relevant excerpts from the En Banc Supreme Court Decision in GR Nos. 163653 and 167689 on the imposition of Documentary Stamp Tax on inter-office memo covering advances granted by an affiliated corporation

Summary

RMC No. 48-2011 circularizes excerpts from the En Banc Supreme Court Decision in Commissioner of Internal Revenue vs. Filinvest Development Corporation, GR Nos. 163653 and 167689 dated July 19, 2011, on Documentary Stamp Tax on inter-corporate loans.

Key points

1. Instruction to BIR employees. BIR employees engaged in the audit and review of audit cases are enjoined to assess deficiency DST, if warranted, on transactions involving an inter-office memo covering advances granted by an affiliated corporation.

Who is affected

• BIR employees engaged in audit and review of audit cases

Deadlines and effectivity

• Decision dated July 19, 2011

Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.