BIR Ruling No. 451-2017

REPUBLIC OF THE PHILIPPINES

DEPARIMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No.

45-17

CERTIFICATE OF TAX EXEMPTION

issued to

THE URSULINE SISTERS OF THE CANADIAN UNION OF THE ORDER OF ST.

URSULA, PHILIPPINES, INC. Capitot Hitl, City of Mati. Davao Oriental

SEC Company Reg. No. TIN:

This certifies that the above-named corporation is a non-stock. non-profit corporation and has proven hy actual operation that, its primary purpose falls under Section 30 (F) of the National Internai Revenue Code of 1997, as amended. it is exempt from INCOME TAX only on the following revenues or receipts:

1. Contributions; and 2. Donations/grants/subsidies. -nothing follows

subject to the provisions of applicable BIR rules and regulations and the tax exemptions. liabilities and responsibilities stated in the Terms and Conditions hereto attached and made an integral part hereof. It is liabie, however, lo all other taxes not enumerated above.

This certification shall bc valid for three (3) years from the date of issuance unless earlier revoked by this Office for violation of any provisions of applicable rules and regulations of BIR. or the terms and conditions herein set forth.

This Certificate may be renewed upon filing of a subscquent application for revatidation provided under Revenue Memorandum Order (RM0) No. 20-2013. Failure to renew this Certificate shall be deemed a revocation thereof upon the expiration of the three (3)-year period.

This Certificate of Tax Exemption is being issued on the basis of the facts and documents as represented and submitted. However. if upon investigation, the BIR ascertains that the facts are different. then this Certificale shall be considered null and void.

Issued this day of

Commissioner of Internal Revenue CAESAR R. DULAY

K-1VDPM14 The Ursuline Sisters of the Canadian Union of the Order of St. tirsuta. Philippines, Inc.

CELIA C.KING CA

Resource Management Group Deputy Commissioner

THE URSULINE SISTERS OF THE CANADIAN UNION OF THE ORDER OF ST. URSULA, PHILIPPINES, INC. CTE No. V O Pagc 2 of 3 Date issued

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

TAX EXEMPTION

1) INCOME TAX. THE URSULINE SISTERS OF THE CANADIAN UNION OF THE ORDER OF ST. URSULA, PHILIPPINES,INC. is only exempt from the payment of Moreover. to be entitled to the tax exemptions enumerated herein. the association/corporation/ organization must continue to meet the requirements set forth under Revenue Memorandum Order No. 20-2013. income tax on revenues and receipts enumerated on the Certificate of T'ax Fxemption

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

to the corresponding internal revenue taxes imposed under the NIRC on its income derived the disposition thercof. which income should be returned for taxation. URSULA, PHILIPPINES, INC. is subject to income tax on a!| its income/receipts/revenues not expressly exempted and stated in the Certificate of Tax Exemption. Moreover, it is subject from any of its properties. real or personal. or any activity conducted for profit regardless of THE URSULINE SISTERS OF THE CANADIAN UNION OF THE ORDER OF ST.

half percent (7-1/2%) final withholding income tax pursuant to Section 27(D)(1) in reiation to Likewise, interest income from currency bank deposits and yieid or any other monetary benefits bank under the expanded foreign currency deposit system shail be subject to seven and one- Sec. 57(A) both of the NIRC. from deposit substitute instruments and from trust funds and similar arrangements. and royalties derived from sources within the Philippines are subject to the twenty percent (20%) final withholding tax: Provided. however, that interest income derived by it from a depository

2) VALUE ADDED TAX

a business pursuit. including transactions incidental thereto, in general. it shall be liable for VAT on the revenues derived therefrom. If THE URSULINE SISTERS OF THE CANADIAN UNION OF THE ORDER OF ST URSULA, PHILIPPINES, INC. is engaged in the sale of goods or services in the course of

Notwithstanding that it is a non-stock, non-profit corporation, its purchase of goods or properties or serviccs and importation of goods shall nevertheless be subject to the 12% VAT pursuant to Sections 106 and 107 of the NIRC.

3) WITHHOLDING TAX

to the withholding tax under Section 79 (A). Chapter XHI, Title II of the NIRC. as implemented by Revenue Regulations No. 2-98, as amended. or if it makes income payments to individuals or corporations subject to the withholding tax pursuant to Section 57 ot the NIRC. as implemented by Revenue Regulations No. 2-98, as amended. URSULA, PHILIPPINES, INC. shall be constituted as withholding agent for the government if it acts as an employer and its employees receive compensation income subject THE URSULINE SISTERS OF THE CANADIAN UNION OF THE ORDER OF ST.

THE URSULINE SISTERS OF THE CANADIAN UNION

Pagc 3 of 3 OF THE ORDER OF ST. URSULA, PHILIPPINES, INC. Date issued_9-62017... CTENO. 41

TAXPAYER'S DUTIES & RESPONSIBILITIES

1) THE URSULINE SISTERS OF THE CANADIAN UNION OF THE ORDER OF ST URSULA, PHILIPPINES, INC. is required to file on or before the 15th day of the fourth incurred during the preceding period and a certificate showing that therc has not been any change in its By-laws, Articles of Incorporation, manner of operation and activities as well as to the aforementioned Annual Information Returr month foilowing the end of the accounting period a Profit and Loss Statement and Balance Sheet with the Annual Information Return under oath, stating its gross income and expenses sources and disposition of income. Copy of this Certificate of T'ax Lxcmption shall be attached

2) Under Section 235 ot the NIRC. any provision of existing general and special law to the organization or grantees of tax incentives shall be subject to examination by the BIR for purposes of ascertaining compliance with the conditions under which it has been granted tax contrary notwithstanding, the books of accounts and other pertinent records of tax-exempt exemptions or tax incentives, and its tax liabilities. if any

3) Further. it is also required under Section 6(C) in relation to Section 237 of the NIRC to issue duly registered receipts or sales or commercial invoices for each sale or transfer of merchandise or for services rendered which are not directly related to the activities for which the Association is registered. (Revenue Memorandum Circular No. [RMC] No. 76-2003).

4) Finally. it is subject to the payment of registration fee of PhP 500.00 as prescribed in Scction 236(B) of the NIRC