BIR Ruling No. 506-2017

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezen City

Certificate of Tax Exemption No.

E-2017

CERTIFICATE OF TAX EXEMPTION

issued to

HIGHER ROCK CHRISTIAN CHURCH, INC. 3/F ESNA Bldg., 30 Timog Avc., Laging Handa. District IV, Quezon City

SEC Company Reg. No. TIN

proven by actual operation that its primary purpose is one of those enumerated under Section 30 (E) of the Nationai Internal Revenue Code of 1997, as amended. It is exempt from INCOME TAX only on thc following revenues or receipts: This certifies that the above-named entity is a non-stock, non-profit corporation and has

2c I . Tithes and offering: Missions. Building fund;

othing follow

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

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

Certificate shall be deemed a revocation thereof upon the expiration of the three (3)-year provided under Revenue Memorandun Order (RMO) No. 20-20i3. Failure to renew this This Certificate may be renewed upon filing of a subsequent application for revalidation

period.

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. This Certificate of Tax Exemption is being issued on the basis of the facts and Issued this day o NOV 0 6 2017

A tawAy

K- Commissioner of Internal Revenue CAESAR R. DULAY 010838

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TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

TAX EXEMPTIONS

1) INCOME TAX.

provided, that no part of its nct income or asset shall belong to. or inure to the benefit of tax oniy on revenucs and receipts enumerated on the Certificate of Tax Exemption any member. organizer. officer or any specific person. HIGHER ROCK CHRISTIAN CHURCH, INC. is exempt from the payment of incomc

LIABILITY FOR INTERNAL REVENUE TAXES

D) INCOME TAX

under the Nationat Internal Revenue Code of 1997, as amended. on iis income derived from HIGHER_ROCK CHRISTIAN CHURCH_INC. is subject to incomc tax on all its incomc/rcceipts/revenues not expressly exenipted and stated in the Certificate of Tax Excmption. Moreover. it is subject to the corresponding internal revenue taxes imposed

disposition thercof. which income should bc returned for taxation. any of its properties, real or personal. or any activity conducted for profit regardless ot the

Dividends and gains on sale of marketable equity securities listed in the Philippine Stock Exchange (PSE), other short-tcrm and tong-term investments are subiect to income tax

benefits from deposit substitute instruments and from trust funds and similar arrangements. and royalties derived from sources within the Philippines are subject to the twenty pcrccnt seven and one-half percent (7-1/2%) final withholding income tax pursuant to Section 27(D)(1) in relation to Sec. 57(A) both of the National Internal Revenue Code of 1997. as Likewise. interest income from currency bank deposits and yield or any other monetary (20%) final withholding tax: Provided. however, that interest income derived by it from a depository bank under the expanded foreign currcncy deposit system shall he subject to amended.

2) VALUE-ADDED TAX

If' HIGHER ROCK CHRISTIAN CHURCH,INC, is engaged in thc salc of goods or services in the coursc of a business pursuit. including transactions incidental thereto. in gencral. it shall be liable for value-added tax on the revenues derived therefrom.

value-added tax pursuant to Sections 106 and 107 of the National Internal Revenue Code of 1997. as amended. 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 subiect to the 12%

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3) WITHHOLDING TAX

HIGHER_ROCK CHRISTIAN CHURCH, INC. shall be constituted as withholding agent for the governnent if it acts as an employer and its employees receivc compensation income subject to the withholding tax under Section 79 (A), Chapter XIII, Title II of the National Internal Revenuc Code of 1997. as amended. 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 of the National Internal Revenue Code of 1997. as amended, as implemented by Revenue Regulations No. 2-98, as amended.

TAXPAYER'S DUTIES & RESPONSIBILITIES

1) HIGHER ROCK CHRISTIAN CHURCH,INC. is required to file on or before the 15th

Statement and Balance Sheet with the Annual Information Return under oath. stating its day of the fourth month foflowing the end of the accounting period a Profit and Loss

gross income and expenses incurred during the preceding period and a certificate showing that 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 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 Revenuc 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 excmptions or tax incentives. and its tax liabilities, if any.

3) Further. it is also required under Section 6(C) in rclation to Section 237 of the National

commercial invoices for each sale or transfer of merchandise or for services rendered which Internal Revenue Code of 1997. as amended. to issue duly registered receipts or sales or

Memorandum Circular No. [RMC] No. 76-2003). are not directly related to the activities for which the corporation is registered. (Revenue

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.