BIR Ruling No. 499-2018

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE Quezon City

Certifieate of Tax Exemption No

499-2018

CERTIFICATE OF TAX EXEMPTION issued to

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: MANILA ARCHDIOCESAN SEMINARY SYSTEM FOUNDATION, INC. San Carlos Pastoral Formation Complex, EDSA, Guadalupe Viejo, Makati City 1254 This certifies that the above-named corporation is a non-stock, non-profit corporation SEC Company Reg. No. TIN:

3.Donations; and 4. Income derived from operation of cafeterias/canteens and bookstores located 1. Subsidy from the Roman Catholic Archbishop of Manila; 2. Board and Lodging of Seminarians; exclusively used for educational purposes. within its premises, owned and operated by MANILA ARCHDIOCESAN SEMINARY SYSTEM FOUNDATION,INC., to be actually,directly and

nothing follows

conditions herein set forth. It 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 integral part hereof. It is liable, however, to all other taxes not enumerated above. for violation of any provisions of applicable rules and regulations of the BIR, or the terms and basis for its income tax exemption. 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 This certification shall be valid from the date of issuance until revoked by this Office

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 MAR 1 4 2018

Maay

K- Commissioner of Internal Revenue CAESAR R.DULAY 014475

Manila Archdiocesan Seminary System Foundation, Inc. CTE No.499-2018 Page 2 of 3 Date issued 3-14-2018

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 Code of 1997, as Amended

TAX EXEMPTION

1) INCOME TAX. MANILA ARCHDIOCESAN SEMINARY SYSTEM FOUNDATION, 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:

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

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% annual basis submit to the Revenue District Office concerned an annual information return and duly audited financial statement together with the following: MANILA ARCHDIOCESAN SEMINARY SYSTEM FOUNDATION, INC.'s interest income final tax and 7 1/2% tax on interest income 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 educational institution it shall on an

earned from passive investment not subject to the 20% final withholding tax and 7 1/2% 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; (a)Certification from their depository banks as to the amount of interest income

(b)Certification of actual utilization of the said income; and

construction and/or improvement of school buildings and facilities, acquisition banks or placed in money markets, on or before the 15th day of the fourth month (c)Board Resolution by the school administration on proposed projects (i.e., of equipment, books and the like) to be funded out of the money deposited in following the end of its taxable year (Sec. 4, Finance Department Order No. 137-87)

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES. Pursuant to Section 109(H) of the NIRC, MANILA ARCHDIOCESAN SEMINARY SYSTEM FOUNDATION, INC.'s gross receipts from operations as a non-stock, non-profit educational institution is exempt from VAT.

LIABILITY FOR INTERNAL REVENUE TAXES

1 INCOME TAX

MANILA ARCHDIOCESAN, SEMINARY SYSTEM FOUNDATION, INC. is subject to Certificate of Tax Exemption. Moreover, it is subject to the corresponding internal revenue taxes income tax on all its income/receipts/revenues not expressly exempted and stated in the

' Department Order No. 149-95 dated November 24, 1995 amending Department Order No. 137-87

Manila Archdiocesan Seminary Systen Foundation, Inc. Page 3 of 3 Date issued 3-14-201& CTE No.499-2018

2) VALUE ADDED TAX or any activity conducted for profit, which income should be returned for taxation, unless said revenues are actually, directly and exclusively used for educational purposes. imposed under NIRC, as amended, on its income derived from any of its properties, real or personal.

Notwithstanding that it is a non-stock, non-profit corporation, its purchase of goods or properties the sale of goods or services in the course of a business pursuit, including transactions incidental thereto, in general, it shall be liable for VAT on the revenues derived therefrom. or services and importation of goods shall nevertheless be subject to the 12% VAT pursuant to Sections 106 and 107 of the NIRC. 1f MANILA ARCHDIOCESAN SEMINARY SYSTEM FOUNDATION, INC. is engaged in

3) WITHHOLDING TAX

income payments to individuals or corporations subject to the withholding tax pursuant to Section 57 of the NIRC, and as implemented by Revenue Regulations No. 2-98, as amended. constituted as withholding agent for the government if it acts as an employer and its employees receive compensation income subject to the withholding tax under Section 79 (A), Chapter XIII Title II of the NIRC, as implemented by Revenue Regulations No. 2-98, as amended, or if it makes MANILA ARCHDIOCESAN SEMINARY SYSTEM FOUNDATION, INC. shall be

TAXPAYER DUTIES & RESPONSIBILITIES

1)MANILA ARCHDIOCESAN SEMINARY SYSTEM FOUNDATION, INC. is required to file as well as sources and disposition of income. Copy of this Certificate of Tax Exemption shall be attached to the aforementioned Annual Information Return. 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 on or before the 15th day of the fourth month following the end of the accounting period a Profit and Loss Statement and Balance Sheet with the Annual Information Return under oath, stating its

3) Further, it is also required under Section 6(C) in relation to Section 237 of the National Interna! 2) Under Section 235 of the National Internal Revenue Code of 1997, as amended, any provision of it has been granted tax exemptions or tax incentives, and its tax liabilities, if any. 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 directly related to the activities for which the Association is registered. (Revenue Memorandum Circular 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 No. [RMC] No. 76-2003)

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