Documentary Stamp Tax on Certificates: BIR Rules Under NIRC Section 188

A certificate issued in the Philippines — including a notary public’s certificate of a fact, a certificate of damage, or a school’s diploma or transcript of records — carries a ₱30.00 documentary stamp tax (DST) under NIRC Section 188, implemented through Revenue Regulations (RR) No. 9-2000. The tax is a flat amount per certificate, unrelated to the value of whatever fact or record the certificate attests to.

What does NIRC Section 188 actually cover? #

Section 188 of the National Internal Revenue Code imposes a flat ₱30.00 documentary stamp tax on certificates — a category of document distinct from the contracts, deeds, and financial instruments that most other DST provisions under Title VII address. Where Sections 174–182 tax shares of stock and debt instruments, and Sections 195–196 tax mortgages and property deeds, Section 188 catches a document evidencing that someone has attested to, certified, or confirmed a fact. Revenue Regulations No. 9-2000, dated August 31, 2000, implements this provision and reiterates the DST payment and remittance mechanics for certificates.

Certificates taxable under Section 188 include those issued by a notary public certifying a fact (as distinct from a plain notarial acknowledgment on an unrelated document), and — in long-standing BIR administrative practice — a diploma or transcript of records issued by an educational institution. This is why schools in the Philippines typically factor documentary stamp tax into the cost of releasing a diploma or transcript to a graduating student, rather than treating those documents as DST-free simply because they are academic rather than commercial in nature.

A legal summary of the section’s operative language, digesting the certificate-DST rule together with its implementing regulation, puts it this way:

“…certificates issued by a notary public are also subject to documentary stamp tax of Thirty pesos (P30.00).”

— legal digest of NIRC Section 188, as implemented by Revenue Regulations No. 9-2000

Notarial certificate vs. a plain notarial acknowledgment — what’s the difference? #

Section 188 targets a certificate as its own distinct document — a notary public certifying a specific fact — not the routine acknowledgment or jurat a notary affixes to an unrelated instrument such as a deed of sale, an affidavit, or a Special Power of Attorney. A Special Power of Attorney notarized by a lawyer, for example, carries its own DST under NIRC Section 193 — a separate ₱10.00 flat rate on the power-of-attorney instrument itself — rather than the certificate rate under Section 188. The two sections tax different kinds of documents, and confusing “a notarized paper” generally with “a certificate” specifically is a common source of DST misclassification.

Does a government office pay this DST too? #

Certificates issued by the Philippine government acting in its sovereign or governmental capacity generally fall outside the documentary stamp tax system altogether, because DST is designed to tax instruments evidencing private-law transactions and dealings rather than the government’s exercise of its regulatory or administrative functions. This is a separate question from the certification fee a government office charges the requesting party — that fee is an administrative charge, not a DST. A private entity issuing the same kind of certificate — a private school’s transcript, or a private notary’s certificate of a fact — does not get the benefit of this government carve-out and remains subject to Section 188.

How is the DST filed? #

DST on a certificate is reported and paid on BIR Form 2000, the Documentary Stamp Tax Declaration/Return, since a certificate is not one of the one-time transactions — real property or unlisted-share transfers — that BIR Form 2000-OT is reserved for. Under NIRC Section 200 and Revenue Regulations No. 6-2001, the return and payment are due within five (5) days after the close of the month in which the certificate was made or issued. See Documentary Stamp Tax (DST): What It Is and When BIR Form 2000 Applies for the shared filing mechanics every recurring DST document follows.

Worked example: a university releasing 500 diplomas in one batch #

A private university in Metro Manila releases 500 diplomas to its graduating batch in a single commencement cycle.

The university reports this ₱15,000 on BIR Form 2000 for the month the diplomas were issued, due within five days after the close of that month. Because the tax is a flat amount per certificate rather than a percentage of any peso value, the computation scales directly with the number of certificates issued in the period — a school issuing 5,000 diplomas across several release batches in a year would owe ₱150,000 in Section 188 DST for the year, spread across whichever months the batches were actually released.

Frequently asked questions #

How much is the documentary stamp tax on a certificate under NIRC Section 188? #

NIRC Section 188 imposes a documentary stamp tax of ₱30.00 on each certificate of damage or otherwise, and generally on other certificates issued by any person, taxable as such under the Tax Code — the same ₱30.00 flat amount applies whether the certificate is issued by a notary public or another private issuer covered by the section.

Is a diploma or transcript of records subject to this DST? #

Yes. Diplomas and transcripts of records are treated as certificates taxable under NIRC Section 188, which is why schools typically affix or remit documentary stamp tax when issuing these documents to graduates and students.

Do notarized documents themselves carry this same DST? #

No — a notary public’s acknowledgment on a document (a jurat or acknowledgment page) is not, by itself, the certificate Section 188 taxes. Section 188 covers certificates issued as a distinct document — such as a notary public’s own certification of a fact, or a certificate of damage — not the notarial act performed on an unrelated instrument, which may separately carry its own DST under the section that applies to that instrument.

Does a government agency pay DST on the certificates it issues? #

Certificates issued by the Philippine government acting in a sovereign, non-proprietary capacity are generally treated as outside the documentary stamp tax system altogether, since DST attaches to instruments evidencing private-law transactions rather than to the exercise of governmental functions. This is distinct from the fees a government office separately charges for issuing the certificate.

How is DST on certificates filed and paid? #

DST on certificates is generally paid through BIR Form 2000, the Documentary Stamp Tax Declaration/Return, filed and paid within five (5) days after the close of the month in which the certificate was issued, per NIRC Section 200 and Revenue Regulations No. 6-2001.

Summary #

NIRC Section 188, implemented by Revenue Regulations No. 9-2000, imposes a flat ₱30.00 documentary stamp tax on certificates — a category that reaches a notary public’s certificate of a fact and, under long-standing administrative practice, diplomas and transcripts of records issued by schools. The tax is per certificate, not tied to the certified fact’s value, and it is distinct from the DST that applies to a notarized instrument such as a Special Power of Attorney or a deed of sale under their own sections. Government-issued certificates in a sovereign capacity generally sit outside the DST system. File and pay through BIR Form 2000 within five days after the close of the month of issuance, alongside the other recurring DST documents covered in Documentary Stamp Tax (DST): What It Is and When BIR Form 2000 Applies.