BIR Ruling No. 662-2019

REPUBLIC OF THE PHHL(PPINES

BUREAU OEUNGFRNAL REVENUE DEPARTMENT OF FINANCE

Certificate of Tax Exemption No. 0662-2019

CERTIFICATE OF TAX EXEMPTION

issued to

CEBU CHILDREN OF HOPE SCHOOL FOUNDATION, INC

I 78-!D Sun Valley Road, V. Rama Avenue, Calamba, Cebu City 6000

FIN: SEC Company Reg. No.

This certifies that the above-named corporation is a non-stock, non-profit corporation and has proven by actual operatio: 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 fron INCOME TAX only' on the following revenues or receipts:

3. Income derived from operation of cafeterias/canteens, dormitories and bookstores located 1. Donations; 2. Misceilaneous Fees; and

within its premises, owned and operated by CEBU CHILDREN OF HOPE SCHOOL FOUNDATIQN, iNC. to be actually, directly and exclusively used for educational purposes.

nothing follow:

subject to the provisions of applicable BiR rules and regulations and the tax exemptions. tiabilities 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.

This certification shall be valid from the date of issuance until revoked by this Office 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 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 Certificate of Tax Exemption is being issued on the basis of the facts and documents as represented and submitte.l. However, if upon investigation, the BIR ascertains that the facts are different, then this Certiicate shall be considered null and void

Issued this day of-0CI 1 8 2019

acx

CAESAR R. DULAY Commissioner of Internal Revenue

029892

K -

CEBU1 CHILEREN OF HOPE SCHOOL FOUNDATION. INC. CTE No:_ 0 6 6 2 - 2 0_1 9

Page 2 of 3 Date issued OCL 1_82019

TERMS AND CONDITIONS

T F THE CERTIFICATE OF TAX EXEMPTION

For Non-Stock, Non-Profit Educational Institution under Secticn 30(H) of the National Internal Revenue Code of 1997, as Amended

TAX EXEMPTION

I. INCOME TAX CEBU CHILDREN OF HOPE SCHOOL FQUNDATION INC. exempt from the pay ment

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 4-4-2016. to wit:

I. 1 Its revenues are actually, directly and exclusively used for It is a non-stock, non-profit educational institution; and educational purposes.

currency bank deposits and yield from deposit substitute instrunents used actually, directly: and CEBU CHILDREN OF HOPE SCHOOL FOUNDATION, INC.'s interest income. from

statement together with the following: exclusively in pursuance of its purpose as an educational institution, are exempt from the 20% Section 27(D)(1) of the National Internal Revenue Code of 1997, as amended, subject to conpliance 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 tinal tax and i5%' tax under the expanded foreign currency deposit system imposed under

{a) by Section 27(D)( i) of the National internal Revenue Code of t.re 20% final withholding tax and 15% tax on interest incone u:ider the expanded foreign currency deposit system imposed Certification from their depository bank as to the amount of i it-rest income earned from passive investment not subject to 1997, as amended.

{b} Certification of actual utilization of the said income: and b

2. VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES CHILDREN OF HOPE SCHOOL FOUNDATION, INC, are exempt from taXation prov ided they are owned and operated by it as ancillary services. Pursuant to Section 109(1}(H) of the N{RC, CEBU CHILDREN OF HOPE SCHOOi FOUNDATIQN, INC.'s gross receipts from operations as a non-stock, non-profii educational institution are exempt from VAT. Moreover. revenues derived from assets used in the operation of cafeterias/eanteens, dormitories and bookstores tocated within the premises of CEBu (C Finance Department Order No. 137-87) buildings and facilities, acquisition of equipment, books and Board Resolution by the school administration on proposed projects (i.e., construction and/or improvement of school 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. +. A

Deparment Order No. 149-95 dated November 24. 1995 amending Department Order No. 137-87 ' Republic Act No. 10963 increased the tax rate trom 7.5% to 156e effective Jan. 1. 2018

CEBU ChHEREN OF HOPE SChOOL FOUNdAtiON, INC. CTE No. Page 5 of 3 Date issued_OCT 1 820 19 0662-2019

LIABILITY FOR INTERNAL REVENUE TAXES

1. INCOME TAX NiRc. as amended. on its income derived from any of its properties, real or personal. or any activity conducted for protit, which income should be returned for taxation. unless said reventes are actually, directly and exchusively used for educational purposes. CEBU CHILDRENOF HOPE SCHOOL FOUNDATION,INC. is subject to income tax on all its income/receipts/revenues not expressty exempted and stated in the Certificate of Tax . Exemption. Moreover, it is subjeet to the corresponding internal revenue taxes imposed under

2. VALUE ADDED TAX/PERCENTAGE TAX do not exceed P3,000,000.00. revenues derived therefrom shall be subject to the 12% VAT, in case the gross receipts from such 5ales exceed Three Million Pesos (P3,000,000.00)', or to the 3% percentage tax, if gross receipts goods or services in the course of a business pursuit, including transactions incidental thereto. its ff CEBU CHILDREN OF HOPE SCHOOL FOUNDATION, INC. is engaged in the sa|e of

Notwithstanding ti.et it is a non-stock, non-profit corporation, its purchase of goods or-properties or serv iees and i.portation of goods shall nevertheless be subject to the 12% VAT pursuant tol Sections 106 and 107 of the National Internal Revenue Code of 1997, as amended] 3. WITHHOLDING TAX withholding agent for the government if it acts as an employer and its enployees receive compensation income subject to the withholding tax under Section 79 (A), Chapter XIH, Title I of the NIRC, as implemented by Revenue Regulations No. 2-98, as amended, or if it makes income payments to individuals or corporations subject to the withholding tax pursuant to Section 57 of the NIRC. and as implemented by Revenue Regulations No. 2-98, as amended. CEBU CHILDREN OF HOPE SCHOOL FOUNDATION, INC. shat be constituted as

TAXPAYER DUTIES & RESPONSIBILITIES

1. CEBU_CHILDREN OF HOPE SCHOOL FOUNDATION INC. is required to file on or shall be attached to the aforementioned Annual Information Return. 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 Annual Information Return under oath, stating its there has not been any change in its By-laws, Articles of Incorporation, manner of operation and activities as wefl as sources and disposition of income. Copy of this Certificate of Tax Exemption gross income and expenses incuited during the preceding period and a certificate showing that F 2. Under Section 235 of the National Internal Revenue Code of 1997, as amended, any provision of examination by the BIR for purposes of ascertaining compliance with the conditions under w hich 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 shatt be subject to

3. Further, it is also :-9uired under Section 6(C) in relation to Section 237 of the Nationat internal No. [RMC] No. 76-2003) invoices for each sate or transfer of merchandise or for services rendered which are not directly Revenue Code o.":997, as amended, to issue duly registered receipts or sales or commercial related to the activities for which the Association is registered. (Revenue Memorandun Circular

+. 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.

Repubiic Act No. 10963 increased the VAT threshold from P1,9!9,500.00 to P3.000,000.00 effective Jan. 1. 208