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Republic of the Philippines, et al. vs. Sunlife Assurance Company of Canada

REPUBLIC OF THE PHILIPPINES, Represented by the COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus SUNLIFE ASSURANCE COMPANY OF CANADA, Respondent.

G.R. No. 158085 | 2005-10-14

D E C I S I O N 
 
PANGANIBAN, J.: 
 
Having satisfactorily proven to the Court of Tax Appeals, to the Court of Appeals and to this Court that it is a bona fide cooperative, respondent is entitled to exemption from the payment of taxes on life insurance premiums and documentary stamps. Not being governed by the Cooperative Code of the Philippines, it is not required to be registered with the Cooperative Development Authority in order to avail itself of the tax exemptions. Significantly, neither the Tax Code nor the Insurance Code mandates this administrative registration. 
 
The Case 
 
Before us is a...