BIR Ruling No. 590-2020

ER H REPUBLIC OF THE PHILIPPINES 8T 1Ayw1aT

DEPARTMENT OF FINANCE

BUREAU QFUNTFRNAL REVENUE Wesy

9430-05902820 Certificate of Tax Exemption No.

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CERTIFICATE OF TAX EXEMPTION

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SAMANTABHADRA EDUCATIONAL INSTITUTE, INC.

1141-1145 Batangas St. corner Jose Abad Santos, Tondo, Manila

+SEC Company Reg. No. TIN:

This certifies that the.above-named corporation is a non-stock, non-profit corporation 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 INCOME

TAX only on the following revenues or receipts:

2. Income derivedfrom the operation of cafeterias/canteens, 1. Tuition and Miscellaneous Fees; and dormitoriesand

bookstores located within its premises, owned and operated by SAMANTABHADRA

EDUCATIONAL INSTITUTE, INC., to be actually, directIy 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 i'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 E04 day.of OCT 1 3 2020

K- Wga (ke J S Commissioner Of Internal Revenue 1owsaa CAESARR:DULAY 036950 O

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SAMANTABHADRA EDUCATIONAL INSTITUTE, INC. Page 2 of 3 Date issued_OCT 1 3 2U20 CTENO.SH30-0590 -20LU

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

For Non-Stock, Non-Profit Educational Institution

under Section 30(H) of the National Internal Revenue Codelof 1997.,as.Amended

TAX EXEMPTION 1) INCOME TAX.SAMANTABHADRA EDUCATIONAL INSTITUTE, INC. is

exempt from the payment of income tax only on revenues'and receipts enumerated on

the Certificate of Tax 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

t It is a non-stock, non-profit educational institution; and I. Its revenues are actually, directly and exclusively used for educational purposes.

SAMANTABHADRA EDUCATIONAL INSTITUTE,INC.'s interest income from

currency bank deposits and yield from deposit substitute instruments used actually,

directly and exclusively in pursuance of its purpose as an educational institution, are exempt from the 20%.final tax and 15%' tax under the expanded foreign currency deposit system imposed under Section 27(D)(1) of the National Internal Revenue Code of 1997,

as amended, subject to compliance with the conditions that.as a tax-exempt institution it shall on an annual basis submit to the Revenue District. Office concerned an annual information return and duly audited financial statement together with the following:

a) Certification from their depository bank as to the ramount of interest incomel

earned from passive investment not subject to the 20% final withholding tax and

15% tax on interest income under the expanded foreign currency. deposit system

imposed by Section 27(D)(1) of the National Internal Revenue Code of 1997, as

amended:

b C) construction and/or improvement of school buildings and facilities, acquisition of equipment; books and the like) to be funded out of the morey deposited in banks Certification of actual utilization of the said income;and Board Resolution by the school administration on proposed projects (i.e..

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-

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2) VALUE ADDED TAX(VAT) ON EDUCATIONAL SERVICES.Pursuant to Section

1091)(H of theNational Internal Revenue Codeof1997, as amended SAMANTABHADRA EDUCATIONAL INSTITUTE,~INC.`s," gross receipts from

operations as a*non-stock, non-profit educational institution are exempt from VAT.

Moreover, revenues derived from assets used in the "operation of cafeterias/canteens, dormitories and bookstores located within the premisesof SAMANTABHADRA

EDUCATIONAL INSTITUTE, INC. are exempt from taxation provided they are

owned and operated by it as ancillary services. rs

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LIABILITY FOR INTERNAL REVENUE TAXES I(

1INCOME TAX S

SAMANTABHADRA EDUCATIONAL INSTITUTE,INC.is subject to income tax

on all its income/receipts/revenues not expressly exempted and stated in the

Certificate of TaxExemption. Moreover, it is subject tothe corresponding internal

revenue taxes imposed under National Internal Revenue Code of 1997, as amended, on its

income derived from any of its properties, real or personal, or any activity conducted for Wgh

I Republic Act No. 10963 increased the iax*ratef T Deparment Order No.149-95 dated Novemher 2, 1995 amending Deparunent Order No. 137-87 roin 7.5% to 15% effective Jan. 1, 2018 B C

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Page 3 of 3 SAMANTABHADRA EDUCATIONAL INSTITUTE, INC. CTENo.-SL 70590-20 2 0 Dat ssued 1 3 2020

2) VALUE ADDEDTAX/PERCENTAGE TAX profit, which income should be returned for taxation, unless said revenues are actually, directly and excluisively used for educational purposes. C i

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.. thereto, its revenues derived therefrom shall be subject to the 12% VAT, in case the gross If SAMANTABHADRA EDUCATIONAL INSTITUTE:INC. is engaged in the sale of goods or services in the course of a business pursuit, including transactions incidental

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. T3

TAXPAYER DUTIES&RESPONSIBILITIES 1) SAMANTABHADRA EDUCATIONAL INSTITUTE, INC., is required to file on or 3) WITHHOLDING TAX income. Copy of this Certificate of Tax Exemptionshall be attached to the aforementioned Annual Information Return. before the 15th day of the fourth month following the end of the accounting period a oath, stating its gross income and expenses incurred during the preceding period and a certificate showingthat there has not been any change in its By-laws, Articles of Incorporation, manner of operation and activities as well as sources and disposition of compensation income subject to the withholding tax under Section 79 (A), Chapter XIII, 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 of the National Internal Revenue Code of 1997, as amended, and as implemented by Revenue Regulations No. 2-98, as amended. Profit and Loss Statement and Balance Sheet with the Annual Information Return under withholding agent for the government if it acts as an employer and its employees receive Title II of the National Internal Revenue Code of 1997, as amerided, as implemented by SAMANTABHADRA EDUCATIONAL INSTITUTE,INC. shall be constituted as e

2) Under Section-235-of the National Internal Revenue Code of 1997, as amended, any incentives shall be subject to examination by the BIR"for purposes of ascertaining incentives, and its tax liabilities, if any. provision of existinggeneral and special law to the contrary notwithstanding, the books of accounts and other ipertinent records of tax-exempt organization or grantees of tax compliance with the"conditions under which it has been granted tax exemptions or tax

3) Further, it is also"required under Section 6(C) in relation t5 Section 237 of the National which are not directly related to the activities for which the Association is registered. Internal Revenue Code of 1997, as amended, to issue duly registered receipts or sales or commercial invoices ifor each sale or transfer of merchandise orfor services rendered Revenue Memorandum Circular No.[RMC] No.76-2003

Ces.

4) Finally, it is subject to the payment of registration fee ofPhP500.00:as prescribed in Section 236(B) of thei National Internal Revenue Code of 1997;as amended.

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