BIR Ruling No. 746-2019

RETU BLICF THE PHILIPPINES

DEARIMENT OF FINANCE BUREAUOFTNTEHNALREVENUE

Qeron City

Cer tificate of Tax Exemption No.

0746-2019

CERTIFICATE OFTAX EXEMPTION

issued to

GRACE CHRISTIAN COLLEGE,INC S to. Domingo St., Grace Village. Apolonio Samson i, Quezon City 1106

TN: SEC. Company Reg. No.

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

and has proven by actual operation. thiat its primary purpose is one of those: enumerated under

Secticn 30(H) of the National Intertial Rever ue Code of 199'7, as amended. It is exempt from

INCOME TAX only on the followng revenues or receipts

1. Tuition fees and other achool tees; and 2 Income derived from the operation of tafeterias/canteens,dormitories and bookstores located within its prenises, owned and operated by GRACE CHRISTLAN

COLLEGE,INC., to be actually, directly and exclusively used for educational

purposes.

-no thing follows.

Subject to the provisions of applieale BIR rules and regula ions and the tax exemptions,

liabilities and responsibilities stated in the Terms and Conditions hereto attached and made an

integral part hereof. It is liable, howe ver, to all other taxes not enumerated above.

This certification shall be valid from the date of issuance until revoked by this Oifice

tor violation of any provisions of applicable rules and regulations cf 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 thne corporation vhich are inconsistent with the

Dasis for its income tax exernption.

This Certificate of Tax Exemption is being issued cn the basis of the facts and

tiocuments as represented and submirted. However, if upon investigation, the BIR ascertains

tihat che facts are different, then this Certific ate shall be considered null and void.

Issuued this. day of DC192019

4u

CAESARRDULAY Commissicner of Internal Revenue

031097 -1-JAC

Page 2 of 3 GRACE CHRISTIAN COLLEGE, INC CTE No. Date issued_IFC 09 201!] 0746-2013

TERMSAND CONDITIONS

OFTHE CERTIFICATE OF TAX EXEMFTION

For Non-Stock.NonProfit EducationalInstitution

uder Section 30(M.of the National. Interual Revenue Code of 1997.as Amended

TAN EXEMPTION

D) INCOME TAX.GRACE CHRI$TIANCOLLEGE,INC.is exempt from the payment of income

tax only on rever ues and receipt enunerated on the Certificate of Tax Exemption. It is

Understood that the school rrust continue to meet che following requisi tes as set forth under Revenue

Mernorandum Order (RMO) No 44-2016, to wit:

Hi. Its revenues are actually, drectly and exclusively used for ecucational purposes. ' It is a non-stock, non-profi: edueational institution; and

RACHCHRISTLAN COLLEGE INCs interest income from cuTency bank deposits and yield

from deposit substitute ir strurnents used actualy, directly and exelusively in pursuance .of its

purpose: as an educational instituticr., are exenpt from the 20% :final tax and 15% tax on interest

inccme under the expanded foreigri urrency deposit system imp.osed umder Section 27 (D) (1) of.

the Nati onal Internal Revenue Code of 199 7, as amended, subject so cornpliance with the conditions

that as a tax-exernpt educational institution it shall on an annual basis subimit to theRevenue Distriet

Office concerned an annual inforrnation return and duly audited financial statement together with

the follo wing:

(a)Certification from thet: depository banks as to the am oun: of interest income earned firom passive investment not sutject -to the 20% firal withholding tax and 15% tax on interest i:nvome untier the expanded foreign currency deposit system irmposed by Section 27 () (1) cf the National Internal Revenue Code of 1997, as amended:

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

(c)Board Resolutien by th: school adrr.inistration on propossed projects (i.e.. construction and/or impre vement of school buildings and facilities, acquisition of equipment, books and :he like) to be funded out of the rnoney 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. 13'7-87)2

2) WALUE ADDED TAX CVAT GN EDUCATIONAL SEHVICES. Pursuant to Section

09(1)H of theNIRC,GRACE CHISTIANCOLLEGE.INC's gross receipts from operations as a non-stock, non-profit eclucatior al instituition is exempt from VAT. Moreover, revenues derived frcm assets used in the operation of cafeterias/canteens, dornitor.es and bookstores located within

the premises of GRACECHRISTIAN COLLEGE.INC.are ex emp t from taxation provided they

are owned and operated by it as arcillary activities.

LIABITYFOR ITERNALREVENUE TAXES

D) INCOME TAX.

GRACECHRISTIANCOLLEGEICissubjectto income taxon all its

income/receipts/revenues not expressiy exenpted and stated in the Certificate of Tax

Republic Act No.10963 increase to15%effective lamuarv L2018

Page 3 of 3 GRACE CHRISTIAN COLLEGE,IVC CTE NO. Date issued_DEC nL 201L $7A6-2019

Exemption. Moreover, it is subjeet to thecorresponding internal revenue taxes imposed under

National Internal Revenue Code of 1997.as arnended, on its incorne 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.

?)WALUE ADDED TAX/PERCEITIAGE TAX

If GRACE.CHRISTIAN.COLLESELNS, is engaged in the sale of goods or services in the

course of a busiress pursuit, including transastions incidentil thereto, its revenues derived

therefrern shall be subject to the: 12%. VAT, in case the gross receipts from such sales exceed Three

Million Pesos (3,000,000.00), or to the 3% percentage tax, if gross receipts do not exceed

3.000,000.00.

Notwithstanding th at it is a nor-stock, non-profit corporation, its purchase of goods or properties

cr services and importaticn of geocs shall revertheless be subject to the 12% VAT pursuant-to:

Sections 106 and 107 of the Natior al Interna. Revenue Code of 1997, as amended.

3)(WITHHOLDING TAX.

GRAC.CHRISTIAN.COLLEGEC. shall be constituted as withholding agent for the

governrnent if it acts as an ernployer ard its empleyees recerve compensation income subject to the

withholding tax under Section79 (A), Chapter XI[I, Title II of the National Internal Revenue Code

f 1997, as amended, as implermented by Revenue Regulations No. 2-98, as amended, or if it makes

iacome payments to individuals or corporations subject to the wichholding tax pursuant to Section

57 cf the National Internal Revenue Code of 1997, as amended, and as implemented by Revenue

Fegulations No. 2-98, as arnended.

TANPAYER DUTIES.SRESPONSIELITIES

GRACECHRISTLANCOLLEGEINC.is requiredo file on orbefcre the 15th day of the fourth

month following the end cf the accounting period a Profit and Loss Staternerit and Balance Sheet With the: Annual Informaticn Returr under oath, stating its gross ir.come and expenses incurred during the preceding period and a certificate showing that there has nor: been any change in its By- laws, Articles of Incorporation, m anner of ope raticn and activities as vell as sources and disposition of incorre. Copy of this Certificarte of Tax Exeinption shall be attached to the aforementioned

Arnual Information Return.

:)Ur.der Siection 235 of the National Irnrternal R.everiue Code of 1997, ns amended, any provision of

exi.scing general and special law to thie contrary notwithstanding, the books of accounts and other pertinent records of tax-exempt organization or grantees of tax in.centives shall be subject to. exaraination by the BIR for purposes of ascertaining compliance with the conditions under which it has been granted tax exe:mptions or tax incentives, and its tax liabilities, if any.

3) Further, it is also rquired under Section 5C) in relation to Section 237 of the National Internal

Revenue Code of 1997, es amenced, to issue culy registered receipts or sales or commercial invoices for each sale or transfer of merchandise or for services rerdered which are not directly related to the activities for which the Associatior. is registered. (Revenue Memorandurn Circular [c. [RMC] No.76-2003).

)Finally, it is subject to the paymert of registrartion fee of P500.00 as prescribed in Section 236 (B)

of the National Internal Revenue Code of 199'7, as. amended

Rept blic Act No. 10963 increased the VAT thnreshoid f-om P1.919,500.00 to P3.000,000.00 effective January 1, 2018.