BIR Ruling No. 83-2018

\, [[wJ REPUBLIC OF T'JE PH]T IPPINES DEPARTMENT OF FINANCE r4ffiz BUREAU OF Q-IuNeTzEoRnNCAifI,y REVENUE Certificate of Tax Exemption No. c8j-a:r8 CERTIFICATE OF TAX EXEMPTION , issued ro Pardo, 6000 Cebu City TIN: SEC Company Reg. No. This certilles that the above-named corporation is a non-stock, non-profit corporatiol and has proven by actual operation that its primary purpose is one of those enumeratecl under Section 30(H) of the National Internal Revenue Code of 1997, as amended. INCOME TAX only on the lollowing revenues ol receipts: It is exempt from l. Tuition Fees and Other school fees; 2' Income derived from the operation of caf'eteriaslcanteens located within its premises, owned and operated by I{oLy R.osAR.y scHool- oF pARDo,INC. to be actually, directry 3' trncome from the sales and excrusivery used for educational purpose; and to be of textbooks, urriforms, patches and similar suppiy actually, directly and'excrusivery usbd for educationar purpose. nothing follows ilsniautebbgijelirtcaietl stpoaarntthdheerepresrpooovf.nisIsitoibinsilsitliiaeobsfleas.tpahpteolidwcaeinbvleethr,eBtToIRearmlrlusolethasenrdatnCadxoernsedgnituoioltanetsionhunemsreeartnoadteadttthaaecbhoteavdex.aenxdemmpadtioenasn, This certification shall be valid from the clate of issuance until revoked by this Office tbr violation of any provisions of applicable rules and regulations of the BIR, or the tems and are material changes in the conditions herein set forth. It shall likewise be revokecl if there 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 issue,l on the basis o[ the facts and documents as represented and submifted. However, 1f upon investigation, the BIR ascertains that the facts are different, then this Certificate shall be considered null and void. Issued this day of JAI-{ : 0 effi&_ K- li spf CAESAR. R. DIILAY Commissioner of internal Revenue I lf.i-,lxa,!-q" fl-,/k c[{.tA c. fitd$&

Hoiy Rosaryr School of Pardo, Inc. CTE No. c8]*:ulE Page 2 of3 Date issued 1^3O*?!:1t TERMS AND CONDITIONS OF TI{E 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 EXEIVIPTION li INCONIE TAX. HO{-Y ROSARY SCHOOL OF PARDO. 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 sclrool rnust contirrue to meet the following requisites as set forth under Revenue Mernorauduur Order (RMO) No '14-201 6, to ivit: i. It is a non-stock, rron-profit educational institution; and i'i. Its reverlues are actually, directly and exclusively used fbr educational purposes. I{OLY ROSARY SCHOOL OF PARDO. INC.'s interest income from currency bank deposits and yicld frorn deposit substitute instrumbnts used actualll', directly and exclusively in pursuauce of its purpose as an educational institution, are exempt frorn the 20ohfinal tax and 1 l12% tax on interest income under the expanded foreign cuffency deposit system irnposed under Section 27 (D) (l) of the National Internal Revenue Code of 1997, as amended, subject to conrpliance with the conditions that as a tax-exempt educational institution it shall on an anltual basis subrnit to tlie Reveuue District Office concerned an annual information retum and duly audited financial statement together with the following: (a)Certification frorn their depository banks as to the amount of interest iucome earned from passive investment not subject to the 20Yo frnal withholding tax and 7 1/2Vo tax on interest income under the expanded foreign currency deposit system imposed by Section 21 (D) (1) of the National Intemal Revenue Code of 1991" as arnended: (b)Cerrification 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 l5th day of the fourth month following the end of its taxable year (Sec. 4, Finance Depaftment Order No. I 37-87)r. 2) VALUE ADDED TAX (VAT) ON EDUC.A.TION.4.L SERVICES, Pursuant to S'.''tior.r 109(1XH) of the NIRC, HOLY ROSARY SCHOOL OF PARDO, INC's vA' gross receipts ,m operatiorrs as a non-stock, non-profit educational institution is exempt fi'om *dA --_.-r;-^ h^-^*,_^h+ n-AoF \t^ '11,1_e1

Holy Rosary School of Pardo, Inc. CTE No. n83*;arB Page 3 ol'3 Date issuerh*:il*4018 X-i,qts[I-IT'Y FCIR. II{TERI\A [, RF],VE,NIIE TAXES 1) INCOME TAX HOLV ROSARY SCHOOL OF PARDO. INC. is sutrject to income tax on all its income/ receipts/ revenues not expressly exempted and stated in the Certificate of Tax Exemption. Moreover, it is subject to the corresponding internal revenue taxes imposed under NIRC, as amended, on its income derived from any of its propefiies, real or personal, or any activity conducted for profit, which income should be returned for taxatibn, unless said revenubs'are actually, direitly and exclusively used for educational purposes. ", 2) VALUE ADDED TAX/PERCENTAGE TAX If I{OLY ROSARY SCI{OOL OF PARDO.INC. is engaged in the sale of goods or seryices in the course" of a business pursuit, including transactions incidental thereto, its revenues derived therefrom shall be subject to the 12oh VAT, in case the gross receipts frgm such sales is One Million Nine Hundred Nineteen Thousand Five Hundred Pesos (PI,919,500.00), orto the 30lo percentage tax,ifgrossreceiptsdonotexceedPl'9l9,500.00. Notwithstanding that it is a non-stock, non-profit corpuration, its purchase of goods or properlies or services and importation of goods shall neveftheless be subject to the 12%YAT pulsuant to Sections 106 and 107 of the NIRC. 3) WITHHOLDING TAX HOIY ROSARY SCHOOL OF PARDO.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 implemented by Revenue Regulations No. 2-98, as amended, or if it rnakes income payments to individuals or corporations sub.ject to the withholding tax pursuant to Section 57 of the NIRC, and as implemented by Revenue Regulations No. 2-98, as amended. .IAXPAYER. DUTIES & RE,SPONSItsfi,ITIES 1) HOLY ROSAR.Y SCHOOL OF PARDO. INC. is required to file on or before the l5th day of the fourth rlonth following the end of the accounting period a Profit and Loss Statement and Balance Sheet with the Annual Inf,ormation 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 income. Copy of this Certif-icate of Tax Exemption shall be attached to the afbrementioned Annual Information Retum. 2) Under.Section 235 of the National lr]ternal Revenue Code of 1997, as amended, any provision of existing general and special law to the contrary nofwithstanding, the books of accounts and otlter pertinent records of tax-exempt organization or grantees of tax incentives shall be subject to examination by the BIR for plrrposes of ascertaining compliance with the conditions under whicli it has been granted tax exemptions or tax incentives, and its tax liabilities, if any. 3) Further, it is also required under Section 6(C) in relation to Section 237 of tlie National Intenral Revenue Code of 1997, as amended, to issue duly registered receipts or sales or commercial invoices for each sale or transfer of merchandise or for services rendered which are not directly related ro the activities for which the Association is registered. (Revenue Memorandum Circular No. [RMC] No. 76-2003). 4)