BIR Ruling No. 456-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No.

Dr-0456-2020

CERTIFICATE OF TAX EXEMPTION

issued to

INTERNATIONAL RICE RESEARCH INSTITUTE 10/F Suite 1009, Security bank Center, 6776 Ayala Avenue, Makati city

TIN:

by INTERNATIONAL RICE RESEARCH INSTITUTE in favor of: This certifies that the Deeds of Donation executed on August 8, 2014 and October 17, 2013,

Name of Donee TIN Address

University of the Philippines System Admin College, Los Banios, Laguna 4031 UPLB Administration Bldg.

covering the following Motor Vehicles described below, to wit;

Make & Type Motor No. Chassis No. Plate No. CR. No. OR No. Body No.

6

1

9

10.

11

2

3

E

D1-0456-2028 AUG 1 8 2020

15

16

17

18

19.

20

21

22

being gifts in favor of the University of the Philippines System Admin, an educational institution, are exempt from the payment of the donor's tax pursuant to Section 101 (A)(2) of the Tax Code of

1997, as amended.

Moreover, Section 185 of Regulations No. 26, otherwise known as the Revised

Documentary. Stamp Tax Regulations, implementing Title VII of the Tax Code, provides that

conveyances of realties not in connection with a sale, to trustees or other persons without

consideration are not taxable. Accordingly, the Deeds of Donation are likewise not subject to the

documentary stamp tax prescribed under Section 196 of the Tax Code of 1997, as amended.

However, the acknowledgements of the Deeds of Donation before a notary public are subject to

the documentary stamp tax of P15.002 imposed under Section 188 of the same Code.

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 day of AUG 1 8 2020

183a1'a

CAESAR R. DULAY Commissioner of Internal Revenue

036386

K-1-JAC

2The old DST rate of P15.00 was used since the donatin took place prior to the effectivity of R.A.No.10963. 1 Renumbered by Republic Act No. 10963 or TRAIN Law.