BIR Ruling No. 71-2020
REPUBLIC OF THE PHILIPPINES
DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE
Quezon City
Certific- f Tax Exemption No.
SH-003-2020
CERTIFICATE OFTAXEXEMPTION
issued to
SLRDC School Bldg., Rizal, San Bartolome, San Leonardo, Nueva Ecija 3 102 SAN LORENZO RUIZ DIOCESAN ACADEMY,INC
TIN: SEC Company Reg. No.
and has proven by actual operation that its primary purpose is one of those enumerated under Section 30(H) of the National Internal Revenue Code of 1997, as amended. It is exempt from This certifies that the above-named corporation is a non-stock, non-profit corporation
INCOME TAX only on the following revenues or receipts:
1. Tuition fees and Other school fees; and
2 Income derived from the operation of cafeterias/canteens, dormitories and bookstores
Iocated within its premises, owned and operated by SAN LORENZO RUIZ DIOCESAN ACADEMY.INC., to be actually, directly and exclusively used for
educational purposes.
-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 liable, however, to all other taxes not enumerated above.
This certification shall be valid from the date of issuance until revoked by this Office
for violation of any provisions of applicable rules and regulations of the BIR, or the terms and
conditions herein set forth. It shall likewise be revoked if there are material changes in the
character, purpose or method of operation of the corporation which are inconsistent with the
basis for its income tax exemption.
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 Certificate shall be considered null and void.
Issued this day ofJAN i 6 202n
1aeaM
CAESAR R.DULAY
K-1-JAC Commissioner of Internal Revenue 032115
Page 2 of 3 San Lorenzo Ruiz Diocesan Academy, Inc. Date issued CTE No.SH-003-2020
TERMS AND CONDITIONS OF THE CERTIFICATE OF TAXEXE T
under Section 30(H of the National Internal Revenue Cotof For Non-Stock,Non-Profit Educational I tu 7s Aonded
TAX EXEMPTION
l) INCOME TAX.SAN LORENZO RUIZ DIOCESAN ACADEMY.INC.is exempt from the Exemption. It is understood that the school must continue to meet the following requisites as set forth under Revenue Memorandum Order (RMO) No 44-2016, to wit: payment of income tax only on revenues and receipts enumerated on the Certificate of Tax
I. It is a non-stock, non-profit educational institution; and ii.Its revenues are actually, directly and exclusively used for educational purposes.
pursuance of its purpose as an educational institution, are exempt from the 20% final tax and 15%l tax on interest income under the expanded foreign currency deposit system imposed under Section the conditions that as a tax-exempt educational institution it shall on an annual basis submit to the statement together with the following: SAN LORENZO RUIZ DIOCESAN ACADEMY, INC.'s interest income from currency bank deposits and yield from deposit substitute instruments used actually, directly and exclusively in 27 (D) (1) of the National Internal Revenue Code of 1997, as amended, subject to compliance with Revenue District Office concerned an annual information return and duly audited financial
and 15% tax on interest income under the expanded foreign currency deposit (a)Certification from their depository banks as to the amount of interest income earned from passive investment not subject to the 20% final withholding tax
system imposed by Section 27 (D) (1) of the National Internal Revenue Code of 1997, as amended;
(b)Certification of actual utilization of the said income: and
(c)Board Resolution by the school administration on proposed projects (i.e. construction and/or improvement of school buildings and facilities, acquisition
of equipment, books and the like) to be funded out of the money deposited in
banks or placed in money markets, on or before the 15th day of the fourth month
following the end of its taxable year (Sec. 4, Finance Department Order No.
137-87)2
2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES. Pursuant to Section
109(1)(H of the NIRC,SAN LORENZO RUIZDIOCESAN ACADEMY.INC.'s gross receipts
from operations as a non-stock, non-profit educational institution is exempt from VAT. Moreover,
revenues derived from assets used in the.operation of cafeterias/canteens, dormitories and
bookstores located within the premises of SAN LORENZO RUIZ DIOCESAN ACADEMY
INC. are exempt from taxation provided they are owned and operated by it as ancillary activities.
LIABILITY FOR INTERNAL REVENUE TAXES
1INCOME TAX
SAN LORENZO RUIZ DIOCESAN ACADEMY.INC.is subject to income tax on all its
income/receipts/revenues not expressly exempted and stated in the Certificate of Tax Exemption
O
San Lorenzo Rui Diocesan Academy, Inc. Page 3 of 3 Date issuedAi5 21 CTE No.SH0032020
Moreover, it is subject to the corresponding internal revenue taxes imposed under National Internal
Revenue Code of 1997,as amended,as amended,on its income derived from any of its properties,real
or personal, or any activity conducted for profit, which income should be returned for taxation, unless
said revenues are actually, directly and exclusively used for educational purposes.
2 VALUE ADDED TAX/PERCENTAGE TAX
If SAN LORENZO RUIZ DIOCESAN ACADEMY,INC.is engaged in the sale of goods or
services in the course of a business pursuit, including transactions incidental thereto, its revenues derived therefrom shall be subject to the 12%VAT, in case the gross receipts from such sales exceed Three Million Pesos (P3,000,000.00)3, or to the 3% percentage tax, if gross receipts do not exceed P3,000,000.00.
Notwithstanding that it is a non-stock, non-profit corporation, its purchase of goods or properties
or services and importation of goods shall nevertheless be subject to the 12% VAT pursuant to Sections 106 and 107 of the National Internal Revenue Code of 1997, as amended.
3)WITHHOLDING TAX
SAN LORENZO RUIZ DIOCESAN ACADEMY,INC. shall be constituted, as withholding agent for the government if it acts as an employer and its employees receive compensation income subject to the withholding tax under Section 79 (A), Chapter XIII, Title II of the National Internal
amended, or if it makes income payments to individuals or corporations subject to the withholding tax pursuant to Section 57 of the National Internal Revenue Code of 1997, as amended, and as Revenue Code of 1997, as amended, as implemented by Revenue Regulations No. 2-98, as
implemented by Revenue Regulations No. 2-98, as amended.
TAXPAYER DUTIES&RESPONSIBILITIES
1 SAN LORENZO RUIZ DIOCESAN ACADEMY INC. is required to file on or before the 15th
expenses incurred during the preceding period and a certificate showing that there has not been any day of the fourth month following 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
change in its By-laws, Articles of Incorporation, manner of operation and activities as well as
sources and disposition of income. Copy of this Certificate of Tax Exemption shall be attached to
the aforementioned Annual Information Return.
2) Under Section 235 of the National Internal Revenue Code of 1997, as amended, any provision of
existing general and special law to the contrary notwithstanding, the books of accounts and other
pertinent records of tax-exempt 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 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 National Internal
Revenue Code of 1997, as amended, 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 P500.00 as prescribed in Section 236 (B
of the National Internal Revenue Code of 1997,as amended.
Want an analysis of this document?
Ask ASG Legal AI to summarize it, compare it with other rulings, or explain how it applies to your situation — it researches from this same library.