BIR Ruling No. 499-2017

REPUBLIG OF THE PHHIPPINES

DEParIMEnI OF FInAnGE BUREAU OF INTERNAL REVENUE

Quczon City

Certificate of Tax Exemption No.

-0

CERTIFICATE OF TAX EXEMPTION

issued to

SOUTH PHILIPPINE UNION CONFERENCE OF THE

SEVENTH-DAY ADVENTIST CHURCH, INC.

Masterson Avenue Upper Carmen Cagayan de Oro City SEC Company Reg. No. TIN:

and has proven by actual operation that its primary purposc is one of those enumerated under Section 30 (F) of the National Internal Revenuc 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 foliowing revenues or receipts:

2. Offerings and contributions. 1. Tithes, donations; and nothing follow

integral part hercof. It is liable, however, to all other taxes not enumerated above. subject to the provisions of applicable BIR rules and regulations and the tax cxemptions. Jiabilitics and responsibilities stated in the Terms and Conditions hereto attached and made an

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

period. provided under Revenue Memorandum Order (RM0) No. 20-20i3. Failure to renew this Certificate shall be deened a rcvocation thcrcof upon the expiration of the three (3)-year This Certificate may be renewed upon filing ot a subsequent application for revalidation

documents as represcnted and submitted. However. it upon investigation. the BIR ascertains that the facts are different. then this Certificate shall be considered null and void. This Certificate of Tax Exemption is being issued on the basis of the facts and Issued this day of NOV 0 5 2017

Uga

Commissioner of Iniernal Revenuc CAESAR R. DULAY 010839

CC: (ffce nf tre Kegtonat DirectorRR16.('ugu)an de (rn(in

Y I oew

Adventist Church, Ine. South Philippine Union Conference of the Seventt: -Day Date issued _11-0---017 CTE No. 490m2017

OF THE CERTIFICATE OF TAX EXEMPTION TERMS ANDCONDITIONS

TAX EXEMPTIONS

D) INCOME TAX.

organizer. officer or any specific person. ADVENTIST CHURCH, INC. is exempt from the payment of income tax only on revenues and receipts enumerated on the Certificate of Tax Exemplion provided that no SOUTH PHILIPPINE UNION CONFERENCE OF THE SEVENTH-DAY part of its net income or asset shall bclong to. or inure to the benefit of any member.

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

Exemption particularly its income from financing and investing activities. SOUTH PHILIPPINE UNON CONFERENCE OF THE SEVENTH-DAY income/receipts/revenues not expressly exempted and stated in the Certificate of Tax ADVENTISTCHURCH,INC. issubjecttoincometax on all its

its properties, real or personal, or any activity conducted for profit regardless of the Moreover, it is subject to the corresponding internal revenue taxes imposed under the disposition thereof, which income should be returned for taxation. National Internal Revenue Code of 1997, as amended, on its income derived from any of

Likewise, interest income from currency bank deposits and yield or any other monetary benefits from deposit substitute instruments and from trust funds and similar arrangements. and royalties derived fron 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 bank under the expanded foreign currency deposit system shall be subject to 27(D)(1) in relation io Sec. 57(A) both of the National Internal Revenuc Code of 1997. as seven and one-half percent (7-1/2%) final withhoiding incomc tax pursuant to Section amended.

2) VALUE ADDED TAX

of a business pursuit. including transactions incidental thereto, in general, it shall be liable If SOUTH PHILIPPINE UNION CONFERENCE OF THE SEVENTH-DAY for value added tax on the revenues derived therefrom. ADVENTIST CHURCH, INC. is engaged in the sale of goods or services in the course

Notwithstanding that it is a non-stock, non-profit corporation. its purchase of goods or of 1997, as amended. properties or services and importation of goods shall nevertheless be subject to the 12% value added tax pursuant to Sections 106 and 107 of the National Internal Revenuc Code

3) WITHHOLDING TAX

SOUTH PHILIPPINE UNION CONFERENCE OF THE SEVENTH-DAY as amended. as implemented by Revenue Regulations No. 2-98. as amended. government if it acts as an employer and its employees receive compensation income 2-98. as amended, or if it makes incomc payments to individuals or corporations subject to the withholding tax pursuant to Section 57 of the National Internal Revenue Code of 1997. ADVENTIST CHURCH, INC. shall be constituted as withholding agent for the subiect to the withholding tax under Section 79 (A). Chapter XII. Title H of the National Internai Revenue Code of 1997. as amended. as impiemented by Revenue Regulations No.

South Philippine (Inion Conference of the Seventl-Day Adventist Church, Inc CTE NO Date issued _11-6-2017 499=2017

TAXPAYER'S DUTIES & RESPONSIBILITIES

I) SOUTH PHILIPPINE ADVENTIST CHURCH, INC. is required to file on or bcfore the 15th day of the fourth UNION CONFERENCE OF THE SEVENTH-DAY

month following the end of the accounting period a Profit and Loss Statement and Balance Shect with the Annual Information Return under oath. stating its gross inconme and expenses incurred during the preceding period and a ccrtificate showing that there has not been any change in its By-laws. Articles of Incorporation. manner ot 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

compliance with the conditions under which i has been granted tax exemptions or tax incentives shall be subject to examination by the BIR for purposes of ascertaining incentives. and its tax liabilities. if any.

3) Further. it is also required under Section 6() 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 directiy related to thc activities for which the Association is registered. (Revcnue Memorandum Circular No.(RMCJ No. 76-2003).

4 Finally. it is subject to the payment of registration fee of PhP500.00 as prescribed in Section 236(B) of the National Internal Revenue Code of 1997. as amended