BIR Ruling No. 909-2018

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT CF PINANCE Quezon Ciry TPE

Certificate of Tax Exemption Ao. S

CERTIFICATE OF TAX EXEMPTION issucd to

PINES INTERNATIONAL ACADEMY. INC. 2 I Cooy eesan Hotel Plaza. Naguilan Rd.. Baguio City

SI.C Company Reg. No.

INCOME TAX only on the following revenues or receipis: and has proven hy 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 this certifies thut the above-named corporation is a non-stock. non-protit corporation

I Receipts from Government Assistance to Private Education (GASTPE ): and Tuition Fees & Other School Reiated Fees: .--

Income derived from the operation of cafeterias/canteens and bookstores located within its premises, owned and operated by Pines used for educational purposes. Internationat Academy. Inc.. to be actually, directty and exciusively

tothing foliov

Tiabilities and responsibilities staled in the Terms and Conditions hereto altached and made an integral par hereof. It is liable. however. to all other taxes not enumerated above. subject to the provisions of applicabie BiR rules and regulations and the tax exemptions

tor violation of any provisions of applicable rules and regulations of the BIR. or the terms and operation ot the corporation which are inconsistent with the basis for its income tax exemption. conditions herein set forth. lt shall tikewise be revoked if there are material changes in the character. purpose or method of This certification shall be valid from the date of' issuance until revoked hy this Oftice

doeuments us represented and submitted. However. if upon investigation. the BIR ascertains that the tacts are different. then this Cenificate shall be considered null and void. This (ertificate of Tax Exemption is being issued on the basis of the faets and

Issued this day ofMAY 2

1Q80

( ommissioner of Internat Res ente CAESAR R. DULAY 016649

P'age 2 of 3 14*.7 *113 Date issued_MA

t nder Section 30 (H) of the National Internal Revenue Code of 1997. as Amended For Non-Stock. Non-Profit Educational institution GF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS A *

LAXEXEMPTON

INCOMF T AX

that the school must continue to meet the following requisites as set forth under Revenue MenorandumOrder (RMO Nc 44-2016. w w it: PINES INTERNATIONAL ACADEMY. INC. is exemPI from the pavmen ot ineome tax onIy on revenues and receipts enumerated on the Certificate of Tax Exemption. It is understood

I. Hts rev enues are actuathy. direety and exelusiveiy used tor educational purpose ..t Is a ton-stoch. non-protit educatonal instulon: and

and y icid from depsit substitute instruments used actally. direetly and exctusively in pursuance ot its purpose as ar educational institution. are exempt from the 20% final tax and +54' tax on interest income under the expanded foreign currency deposit system imposed under Section 27 (D) : i ot the National Intemal Revenue Code ot +997. as amended. subject to compliance w ith the Revenue District Office concerned an annuai information return and dul audited financial statentent together w ith the follos ing. PINES INTERNATIONAL ACADEMY. INC.'s interest income from currency bank deposits conditions that as a tax-exempt educational institution it shall on an annual basis submit to the

(a)Certification from their depository banks as to the amount of interest income earned from passive investment not subject to the 20% final w ithholding lax and 15% tax on interest income under the expanded foreign currency deposii Sy stem imposed by Section 27 (D) ( 1i of the National Internal Revenue Code of 1997. as amended:

(b Cenification of actual utilization of the said income: and

(c+Board Resolution bs the school administration on proposed projects ti.e.. construction and or improvement of school buildings and facilitiea. acquisition of equipnent. hooks and the likei to be funded out of' the money deposited in. banks or placed in money markets. on or before the I Sth day of the fourth moith tollowing the end ot its laxable year (Sec. 4. Finance Department Order No. 13--87

*: VALUE ADDEI) TAX (VAT ON ED(CATIONAL SERVICES

Pursuant to Seeuon 109H of the National' internat Revenue Code of jo97. PINES INTERNATIONAL ACADEMY. INC.'s gtoss receipts irom operations as a non-stock. non- profit educational instiution are exempt trom VAT. Moreover. revenues derived trom assets used in the operation of caieteriascanteens and bookstores located within the premises of PINES INTERNATIONAL ACADEMY. iNC. are exempt from taxation provided they are owned and operated hy it as ancitlary activ ities

Page 3 o{[3 1 Date issaed MA CTE No 2 tu0

LABILITY FOR INTERNAL REVENUE TAXES

H:INCOME HAX

income-receipustrevenues not expressty exempied and stated in the Certificate of Tax conducted for proti. which income should be returned for taxation. tnless said revenues are aetually. Jureetiy and exelusiv eh used for educational purposes. RI\FS INTERNATIONAL ACADEMY. ING.is subject to income taX on al its MRe . as amended. on its meome derived from any or its properties. real or personal. or an aetis iy Lxemption. Aloreoer. H is subjeet to the eorresponding internal revenue taxes imposed under

2: VALUE ADDED TAX . PERCENTAGE TAN

Ht PINES INTERNATtONAL ACADEMY,INC. is engaged in the sale of' goods or sers ices in therefrom shall be suhieet to the 12"e VAT. in case the gross receipts trom such sales exceed Three Million Pesos ( P3.000.000.001. or to the 3%% percentage tax. if gross receipts do not exceed P3.000.00.00 ie course ot a business pursuit. inctuding transactions incidental thereto. its resenue deried

Notwithstanding that it is a non-stock. non-protit corporation. is purchase of goods or properties or services and imporation of goods shall nevertheless be subject to the 12% VAT pursuant to Sections 106 and 107 of' the Nationat Internal Revenue Code of 1997. as amended.

3:WITHHOLDING TAX

Revenue Regulations No. 2-98. as amended. or it it makes income pay ments to individuals or governnent it it aets as an employer and its employ ees reeeis e compensation ineome suoject w the by Rev enue Regulations No. 2-98. as anended PINES INTERNATIONAL ACADEMY. INC. shalI be constituted as wjutholding ugent for the withhulding tax under Seetion 70 (A,. Chapter XHH. Tite H of the NiRC. as implemented h) Corporations subject to the withholding tax pursuant to Seetion 57 of the NIRC. and as impienented

TAXPAYER DUTIES & RESPONSIBILITIES

i } PINES INTERNATIONAL ACADEMY,INC.is required to fite on or hefore the t5th dav of the Sheet with the Annual information Return under oath. stating its gross income and expenses incurred during the preceding period and a cerificate showing that there has not been any change tourth month foftow ing the end of the accounting period a Profit and Loss Statement and Baiance m its By -laws. Articles of Ineorporation. manner of operation and activities as well as sources and aforementioned Annual Information Return. disposition of incone. Copy ot this Certificate of Tax Exemption shall be atached to the

2: l nder Section 235 of the National Internal Revenue Code ot 1997. as amended. any provision ot exising general and special law to the contrary notwithstanding. the books of aceounts and other pertinent records of tax-exempt organization or grantees of tax ineentises shat he subiect to examination hy the BIR for purposes of ascertaining complianee with the conditions under which it has been granted vas exemptions or tax ineentises. and its tax Jiabifities. if any.t

T urthel. 1: is aiso reyuired under Seetion 6tCs in relation to Section 2:- ot the Nationat internat Revenuc ( ode of (oo-. as amended. to issue duly registered receipts or sales or comnereiat

invoiees for each sale or transter ot merehandise or for ser ices rendered which are mt ditects reiaied u the activ nies tor whieh the Assoeiation is registered. tRevenue Memorandum C ireula Y{RA1j \6203}

4:Finally. I ts subieet ts the payment of registration fee of PhP S00.00 as preserihed in Seeton 23o B+ ot the Nationa! Interna Revenuc G ode of 19c-. as amended