BIR Ruling No. 444-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No. SH30-0444-20Z0

CERTIFICATE OF TAX EXEMPTION

issued to

Garcia Corporate Tower, Rizal cor. Grania Sts.. Brgv. 5, Lucena City, Quezon 4301 QUEZON CENTER FOR RESEARCH & STUDIES,INC. SEC Company Reg. No. TIN:

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: This certifies that the above-named corporation is a non-stock, non-profit corporation and

3. Income derived from the operation of cafeterias/canteens, dormitories and bookstores 2.Tuition and Miscellaneous Fees; and 1. Donations and Grants; educational purposes. located within its premises, owned and operated by QUEZON CENTER FOR RESEARCH & STUDIES, INC., to be actually, directly and exclusively used for

nothing follows

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

violation of any provisions of applicable rules and regulations of the BIR, or the terms and 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 basis for its income tax exemption. This certification shall be valid from the date of issuance until revoked by this Office for

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 documents

Issued this day ofAUG 1 7 2020

Haeavweo

K -1/spf-17-245 Commissioner of Internal Revenue CAESAR R. DULAY 036369

QUEZON CENTER FOR RESEARCH & STUDIES, INC. Page 2 of 3 CTE No._SH 30 .044 4 -02 0 Date issued AUG"1 7 2029

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

QUEZON CENTER FOR RESEARCH & STUDIES,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:

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

QUEZON CENTER FOR RESEARCH & STUDIES,INC.'s interest income 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% final tax and i5%' tax 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 institution it shall on an annual basis submit to the Revenue District Office concerned an annual information return and duly audited financial statement together with the following:

(a)Certification from their depository bank as to the amount of interest income earned

from passive investment not subject to the 20% final withholding tax and 15% tax

Section 27(D)(1) of the National Internal Revenue Code of 1997, as amended. on interest income under the expanded foreign currency deposit system imposed by

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

(c)Board Resolution by the school administration on proposed projects (i.e., construction and/or improvement of school buildings and facilities, acquisition of

equipment, books and the like) to be funded out of the money deposited in banks or placed in money markets, on or before the 15th day of the fourth month following

the end of its taxable year (Sec. 4, Finance Department Order No. 137-87)2.

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES

Pursuant to Section 109(1)(H) of the NIRC, QUEZON CENTER FOR RESEARCH &

STUDIES, INC.'s gross receipts from operations as a non-stock, non-profit educational institution are exempt from VAT. Moreover, revenues derived from assets used in the operation of cafeterias/canteens, dormitories, and bookstores located within the premises of QUEZON

CENTER FOR RESEARCH & STUDIES, INC. are exempt from taxation provided they are

owned and operated by it as ancillary services.

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

QUEZON CENTER FOR RESEARCH& STUDIES,INC.is subject to income tax on all

its income/receipts/revenues not expressly exempted and stated in the Certificate of Tax

2 Department Order No. 149-95 dated November 24, 1995 amending Department Order No. 137-87 Republic Act No. 10963 increased the tax rate from 7.5% to 15% effective Jan. 1, 2018 O

QUEZON CENTER FOR RESEARCH & STUDIES, INC. CTENo. SH 3D -0 4 4 4 - 20 20

Page 3 of 3 Date issued AUG t 7 2020

NIRC, as amended, on its income derived from any of its properties, real or personal, 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. Exemption. Moreover, it is subject to the corresponding internal revenue taxes imposed under

2) VALUE ADDED TAX/PERCENTAGE TAX revenues derived therefrom shall be subject to the 12% VAT, in case the gross receipts from such sales exceed Three Million Pesos (P3,000,000.00)3, or to the 3% percentage tax, if gross receipts do not exceed P3,000,000.00. If QUEZON CENTER FOR RESEARCH & STUDIES,INC. is engaged in the sale of goods or services in the course of a business pursuit, including transactions incidental thereto, its

Notwithstanding that it is a non-stock, non-profit corporation, its purchase of goods or 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% VAT

3)WITHHOLDING TAX Section 57 of the NIRC, and as implemented by Revenue Regulations No. 2-98, as amended. income payments to individuals or corporations subject to the withholding tax pursuant to 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 QUEZON CENTER FOR RESEARCH & STUDIES, INC. shall be constituted as

TAXPAYER DUTIES & RESPONSIBILITIES

1) QUEZON CENTER FOR RESEARCH & STUDIES, INC. is required to file on or before has not been any change in its By-laws, Articles of Incorporation, manner of operation and Exemption shall be attached to the aforementioned Annual Information Return. activities as well as sources and disposition of income. Copy of this Certificate of Tax 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 gross income and expenses incurred during the preceding period and a certificate showing that there

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 accounts and to examination by the BIR for purposes of ascertaining compliance with the conditions under which it has been granted tax exemptions or tax incentives, and its tax liabilities, if any. other pertinent records of tax-exempt organization or grantees of tax incentives shall be subject

3)Further, it is also required under Section 6(C) in relation to Section 237 of the National Internal invoices for each sale or transfer of merchandise or for services rendered which are not directly Revenue Code of 1997, as amended, to issue duly registered receipts or sales or commercial related to the activities for which the Association is registered. (Revenue Memorandum Circular 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.

Republic Act No. 10963 increased the VAT threshold from P1,919,500.00 to P3,000,0000 ffective Jan. 1. 2018