BIR Ruling No. 647-2019

HEFUELICOF FHA HIIPINES

BYIREAU CE INTERNALREVENUE DERMENF FINNCE

ue2Ja Cit

[Certificate ot Tax Exemption No.

3047-2n12

CERTIFICATE OF TAX EXEMFTION

issued i0

ST.MARYS DOMMICNSCHOOL INC

Rizal St.. Guiset Norte. S.. Manuel. Panigasinan 2438 OFSANMANUEL.FANGASINAN

SEC Conpany Reg. No. TIN

Trs e ertites that the above-named co-porauon is a non-stock, non-profit coiporation ant H pre-en by aetual operatior that tts orimary purpose is one of those enumerated under Sesuic.. 3o H) cf tne Naional Internal Raverue Code of 1997, as amended. It is exempt frorm Nc. Me T-X oniy on the foliowing re enues or receipts:

ineofne derived from the oteretior of eafeterias/canteens, dormitories and bookstores Faidon fees and other schoel fees; and Rceated withia its premists, OWied and operated by ST. MARY'S DOMINICAN exciusively ased icr educationat purposes. SCHOOL,INC. OF SAN MANUEL, PANGASINAN, to be actaally, directly and

nteing fcllows

Suci-et ic the provisions of applicatie BIR rules and regulations and the tax exempuions. :oiliri- ars responsibilities stated in the Terns &nd Conditions hereto attached and made an Ire-ra eari nerecf. it is liabie, however. o al other taxes not enurmerated above.

Tn : -erificarion shall be valia froin he daie of issuance until revoked by this Office to. iclaion of any provisions of app icabi- ules and regulations of the BiR, or the terans and .orditons rerein ser forth. it shall Hkewise be revoked if there are material changes in the tkarae.er cupose or niethod of operansr. cf the corporation which are inconsistent with the saeis for ite neeire tas exenptior

Tris Certifieate of Tax Exerttion is being issued on the tasis of the faets and acetmteris ss represented and submittel. However. if upon investigation, the BIR ascertains that te facts are difrerent, then this Cerrificate shall be considered null and void

Issued this. day of **:.

N G

Tommissioner of internal Kevenue CAESAR R. DULAY

E- 02985g

St. Mnry's Dontnican School, Inc. ef Sar Manuel Pangusinan Page 2 of 3 Date iss ued_ct CTE NO. 0317-2U18

TERMS AND CONDTIONS OF THE CERTIFICATE OF TAX EXEMPTION For Non-Stock Nan-Prsit Educauonal Institution ander Sestion 30(M of the Natioaal ntzralKevenus Code of 1997.as Amended

TSX EXEMFTION

I ENCOME TAX. ST_MARY'S.DOMNCAN SCHOOL..INC..OF.SAN MANUEL

PaNGasiNaN is exempt from the payment of income tax only on revenues and receipts enunerated on tie Certificate or Tax- Exettiptiem. It is understood that the school must continue to meet the foflowing requisites as set forth under Revenue Menorandum Order (RMO) No 44-

2016, to wit

it is a non-stoek, nor-profit eaucatonal institution; and H.. Hts revenues are aetually, dire.tly and exelusively ased for educarional purposes.

ST.MARY'S DOMINCAN SCEOOL INC.OF SANMANUEL PANGASINAN'S TEVeRES from hospital operations are subject to ten (10%) corporate income tax pursuant to Section 17(B) of the NIRC. Provided that if the grass incone from non-hospital operations exeeeds 50e cf the total gross inconte from all sourees, the entire taxable income from hospital and Hon-hospital operations shall be subiect to the 30% regular income tax.

ST. MARY'S DOMINCAN SCHOOLLIC.OF SAN MANUEL PANGASINAN'S intereSt income frorr: currency bank deposits and yield from deposit substitute instruments used actually.. directiy and exclusively in pursuance of its pu pose as an educational institution, are exempt from the 20% firal tax and 15%' tax on interest income under the expanded foreign currency deposit Systen imposed under Section 27 (D) (7) cf the National Internal Revenue Code of 1997, as

unencied. subject to comphance with the sonditions that as a tax-exempt educational institution it shait on an annual basis submit to the Revenue District Office concerned an annuai information retun ard iuly audited finaneial statenert rogether with the following:

(atCerirication from therr depository banks as to the amount of interest income sarned from passive investment not subject to the 20% final withholding tax and 15% tax on interest inccmie :tader the expanded foreign currency deposit Sy sten irnposed by Section 27 (D) (1) of the National Internal Revenue Code ot Y997. as amended;

(biCertification of actual atilization ot the said income; and

(c)Board Resoluticn by the scnect adrministration or: proposed projects (i.e.. construction ana/or improveffren cf school buildings and facilities, acquisition of equipment, books and the lie: ro be funded cut of the money deposited in banks or placed in money markets. Ji or before the 15th day of the fourth month foilowing the end of is taxable year +See. 4, Finance Department Order No. 137-872.

2) VALUE ADDED TAX (VAT, ON FDUCATIONAL SERVICES. PurSuant tO SectiOn

1O9(1XH) Sf the NIRC, ST.MARY'S DOMNICAN 3CHOOL.INC.OF SAN MANUEL

FaNGasaN's gross receipts from operations as a non-stock, non-profit educational institution is exempt fron VAT. Moreover, feverues derived from assets used in the operation of cafeterias/canteens, dornitories and bookstores ioeated within the premises of ST. MaRY's DGMINICANSCHCOL.INC.OF SAMAINUEL.PANGSINAN are eXempt from taxation provided they are owned and operated by ii as ancillary activities.

St M's Daninican School,Inc. of Sue Mnf, Pangusinan Page 3 oi'3 CTE NO. Date issued, UCT 837701S X

LIABILITY FORINTERNALREVENUETAAES

1, INCOME TAX

ST MARY'S DOMINICAN SCHOOL INC.OF SAN MANUELLPANGASINAN iS SIEjeCt to inconte ax on all irs incorne/receipis/revenues not expressly exempted and stated in tte Certificate of Tax Exemption. Moreover. it is subiect to the corresponding internal revenue taxes inposed ur:der NiRC, as amended. on its ineome derived from any of its properties, real or personai. Sr ary zeti-iry conducted for profit, which income shouid oe returned for taxation, unless said revenues are actualiy. directiy and exetusively used for edueational purposes.

Z) VALUEADDEDTAX/PERCENTACE TAX

I SI_MARY'S DOMIMCAN SCHOOL, INC.OF SAN MANUEL. PANGASINAN IS engaged in the saie of goods or services ir. the course of a business pursuit, including transactions in eider tal thereto, its revenues derived thereicm shall be subject to the 12% VAT, in case the gross receipts froin such sales exeeed Three Mition Pes05 (P3,000,000.00), or to the 3% percentage tax, if gross receipts do not exceed F3,000,000 o6.

Notwithstarding that it is a non-stock, non-prefi corporation, its purchase of goods or propegies Sr ser ices and importation of goods shali revertheiess be subject to the i2% VAT pursuant to Seetions 106 and 107 cf the NIRC.

3; WITHHOLDING TAX

ST.MARY'S DOMNICAN SCHCOL.IC.OF SAN MANUEL.PANGASINAN shall be corstituted as withhoiding agent for the 2overnment if it acts as an employer and its employees recerve eomnpensation income subjecr tc tne withhciding tax under Section 79 (A), Chapter XI Title ii cf che NIRC, as impiemented byy Revenue Regulations No. 2-98, as amended, or if it makes ncone payarents to individuals or corpoiaticns subject to the withholding tax pursuant to Section 57 of the NIRC, and as implenented by Revenue Regulations No. 2-98, as amended.

TAXPAYER DUTIES & RESPONSIBILITIES

!. ST. MRY'S DGMNIC.N SCHOGA.LC.OF SAN MANUEL. PANGASINAN iS reqUired

to fiie on or before the 15th day or tns fearth. nonth foilowing the end of the accounting pericd a Profit and Loss Statemert and Ealarce Sleet with the Annual Infcrmation Return under oath, stating irs gross income and experses incur.eo during the preceding period and a certificate showing tiat inere has not been any change in is By-tews, Ar:icles of Incorporation, manner of operation and acuivities as well as sources and Hisposition ot income. Copy of this Certificate ef Tax Exemption shail be attached to the aferementioned Annual Information Return.

2, Cnder Seeticn 235 sf the Nationai interna. Revenue Code of 1997, as amended, any provision of

ex sting general and special law to the contrary notwithstanding, the books of accounts and other pertineni records of tax-exempt orgatization or grantees of tax incentives shall be subject to exarninarion by the BiR for purposes ot ascertaining conpliance with the conditions under which I has been granted tax exemptions or tax Heentives, and its tax liabilities, if any.

3) Further, i is also required under Secto: 6(C) in relation to Section 237 of the National Iaternal

Reverue Code of 1997, as amendea. to issue duiy registered receipts or sales or cominereial inveiees for each saie cr transfer of nerchandise or for serviees rendered which are not directly reiated to the aetivities for which the Asscciation is registered. (Revenue Memorandum Circular No. (RMC} No. 76-2003)

4) Finaily. it is subject to the payment of regist'7tion ree of Phf 500.00 as prescribed in Section 236

(B) of the National Internal Revenue Cote ef 1997, as amended.