BIR Ruling No. 665-2017

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

Certificate of Tax Exemption No. 665-2017

CERTIFICATE OF TAX EXEMPTION

issued to

36th St. University Park. Port Bonifacio Global City, Taguig. Metro Manila 1604 SEC Company Reg. No. BRITISH EDUCATION INC. TIN:

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: This certifies that the abovc-namcd corporation is a non-stock. non-profit corporation

1. Tuition fees and Other school fees; and

Income derived from operation of cafeterias/canteens and bookstores located within its premises, owned and operated by BRITISH EDUCATION, INC., to be actually. directly and exclusively used for educational purposes.

-nothing follows.

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

basis for is income tax exemption. for 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 matcrial changes in the character, purpose or method of operation of the corporation which are inconsistent with the 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 ou the basis of the facts and

Issued this - day of DEC 2 0 2017

C 0

K- Commissioner of Internal Revenue CAESAR R. DULAY ::011962

British Education, Inc. Page 2 of 3 CTE No. Date issued 12-20-2017 665-2017

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

BRITISH EDUCATION, 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 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 annual basis submit to the Revenue District Office concerned an annuat information return and duly audited financial statement together with the following:

(a)Certification from their depository banks as to the amount of interest income 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;

(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 1 5th day of the fourth inonth 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(1)(H) of the NIRC, BRITISH EDUCATION, INC.'s gross receipts from operations as a non- stock, non-profit educational institution is exempt from VAT. Moreover. revenues derived from assets used in the operation of cafeterias/canteens and bookstores located within the premises of BRITISH EDUCATION, INC. are exempt from taxation provided they are owned and operated by it as ancillary activities.

British Education, Inc. Page 3 of 3 CTE No. Date issued 12-20-2017 665-2017

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX.BRITISH EDUCATIONINC.is subject to income tax on all its

income/receipts/revenues not expressly exempted and stated in the Certificate of Tax 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 Exemption.Moreover,it is subject to the corresponding internal revenue taxes imposed under

are actually, directly and exclusively used for educational purposes.

2 VALUE ADDED TAX.If BRITISH EDUCATION.INC.is engaged in 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

Notwithstanding that it is a non-stock, non-profit corporation, its purchase of goods or properties or services and importation of goods shall nevertheless be subjectto the 12% VAT pursuant to Sections 106 and 107 of the NIRC.

3WITHHOLDING TAX.BRITISH EDUCATION,INC.shall be 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 individuals or corporations subject to the withholding tax pursuant to Section 57 of the NIRC, and implemented by Revenue Regulations No.2-98.as amended, or if it makes income payments to

as implemented by Revenue Regulations No.2-98, as amended.

TAXPAYER DUTIES& RESPONSIBILITIES

BRITISH EDUCATION,INC.is required to file 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 income.Copy of this Certificate of Tax Exemption shall be attached to the aforementioned Annual Annual Information Return under oath, stating its 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 as well as sources and disposition of Information Return.

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. 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

3 Further, it is also required under Section 6C in relation to Section 237 of the National Internal No. [RMC] No. 76-2003). 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 Revenue Code of 1997, as amended,to issue duly registered receipts or sales or commercial

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 N