BIR Ruling No. 386-2018

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No. 32--5013

CERTIFICATE OF TAX EXEMPTION

issued to

AYALA FOUNDATION, INC. 6768 Ayala Ave. cor. Paseo de Roxas 10/F Ayala Wing BPI Main Bldg SEC Company Reg. No. TIN: Makati City 1226

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

i. Grants and Donations.

nothing follows

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

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

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

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 of-HAR u82018

K-1-JAC Commissioner of. Internal Revenue CAESAR R. DULAY Aewcmy 014140

Ayala Foundation, Ine. Page 2 of 3 CTE No. Date issued3- 28 :::wP21

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

TAX EXEMPTION

1) INCOME TAX. AYALA FOUNDATION INC. is only exempt from the payment of income tax on revenues and' receipts 'enumerated on the Certificate of Tax 'Exemption. association/corporation/ organization must continue to meet the requirements set forth Moreover, to be" entitied to thetax"exemptions. under Revenue Memorandum Order No. 20-2013. enumeratedherein, the

LIABILITY FOR INTERNAL REVENUE TAXES 1) INCOME TAX

or personal, or any activity conducted for profit regardless of the disposition thereof, which income should be returned for taxation. subject to the corresponding internal revenue taxes imposed under the National Internal Revenue Code of 1997, as amended, on its income derived from any of its properties, real AYALA FOUNDATION, INC. is subject to income tax on all its income/receipts/revenues not expressly exempted and stated in the.Certificate of Tax Exemption. Moreover, it is

27(D)(1) in relation fo Sec. 57(A) both of the National Internal Revenue Code of 1997, as amended. seven and one-half percent (7-1/2%) final withholding income tax pursuant to Section 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 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 bank under the expanded foreign currency deposit system shall be subject to

2) VALUE ADDED TAX/PERCENTAGE TAX

therefrom shall'be subject to the 12% VAT, in case the gross receipts from such sales exceed One"Million' Nine "Hundred Nineteen Thousand " Five" Hundred "Pesos (P1.919.500.00), or to the 3% percentage tax, if gross receipts do not exceed P1,919,500.00. If AYALA FOUNDATION, INC. is engaged in the sale of goods or services in the course of a business pursuit, including transactions incidental "thereto, its revenues derived

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

3) WITHHOLDING TAX

withholding tax pursuant to Section 37 of the National Internal Revenue Code of 1997, as Revenue Code of 1997, as amended, as implemented by Revenue Regulations No. 2-98, as amended, as implemented by Revenue Regulations No. 2-98, as amended. amended, or if it makes income payments to individuals or corporations subject to the if it acts as an employer and its employees receive compensation income subject to the withholding tax under Section 79 (A); Chapter XIII, Title H of the National Internal AYALA FOUNDATION, INC, shall be constituted as withholding agent for the government

TAXPAYER'S DUTIES & RESPONSIBILITIES

Page 3 of 3 Ayala Foundation, Inc. CTE No.386-2018 Date issued 3-8-2018

1) AYALA FOUNDATION INC. is required to file on or before the 15th day of the fourth 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. month following the end of the accounting period a Profit and Loss Statement and Balance incurred during the preceding period and a 'certificate showing that there has not been any Sheet with the Annual Information Return under oath, stating its gross income and expenses

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 incentives shall be subject to.examination by the BIR for purposes of ascertaining incentives, and its tax liabilities, if any. . accounts :and other pertinent 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(G) in relation to Section 237 of the National 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 Internal.Revenue Code of 1997; as amended, to issue duly registered receipts or sales or Memorandum Circular No. [RMC] No. 76-2003).

4} Section 236(B) of the National Internal Revenue Code of 1997, as amended. Finally. it is subject to the payment of registration fee of PhP 500.00 as prescribed in