BIR Ruling No. 310-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No. SH30-0310-2020

CERTIFICATE OF TAX EXEMPTION

issued to

708 Sta Elena St., Brgy. 293, Zone 28, Binondo, Manila 1006 TIONG SE ACADEMY, INC. SEC Company Reg. No. TIN:

30(H) of the National Internal Revenue Code of 1997, as amended. It is exempt from INCOME has proven by actual operation that its primary purpose is one of those enumerated under Section TAX only on the following revenues or receipts: This certifies that the above-named corporation is a non-stock, non-profit corporation and

1. Tuition and Miscellaneous Fees; and 2. Income derived from the operation of cafeterias/canteens, dormitories and bookstores located within its premises, owned and operated by TIONG SE ACADEMY, 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. subject to the provisions of applicable BIR rules and regulations and the tax exemptions. liabilities and responsibilities stated in the Terms and Conditions hereto attached and made an

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

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 on the basis of the facts and documents

Issued this day ofJUN 0 9 2020

10u3om1y

K- Commissioner of Internal Revenue CAESAR R.DULAY Dw 034107

TIONG SE ACADEMY, INC. Page 2 of 3 CTE No. Date issued S43-0310-2020 JUN 0 9202U

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION under Section 30(H) of the National Internal Revenue Code of 1997, as Amended For Non-Stock, Non-Profit Educational Institution

TAX EXEMPTION D) INCOME TAX. 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 TIONG SE ACADEMY, INC. is exempt from the payment of income tax only on under Revenue Memorandum Order (RMO) No 44-2016, to wit:

i It is a non-stock, non-profit educational institution; and

Ii. Its revenues are actually, directly and exclusively used for educational purposes.

the National Internal Revenue Code of 1997, as amended, subject to compliance with the conditions that as a tax-exempt institution it shall on an annual basis submit to the financial statement together with the following: its purpose as an educational institution, are exempt from the 20% final tax and 15%' tax under the expanded foreign currency deposit system imposed under Section 27(D)(1) of Revenue District Office concerned an annual information return and duly audited TIONG SE ACADEMY, INC.'s interest income from currency bank deposits and yield from deposit substitute instruments used actually, directly and exclusively in pursuance of

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

earned from passive investment not subject to the 20% final withholding tax and 15% 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 the fourth month following the end of its taxable year (Sec. 4, Finance deposited in banks or placed in money markets, on or before the 15th day of Department Order No. 137-87)2.

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES.

amended, TIONG SE ACADEMY, INC.'s, gross receipts from operations as a non- Pursuant to Section 109(1)(H) of the National Internal Revenue Code of 1997, as stock, non-profit educational institution are exempt from VAT. Moreover, revenues derived from assets used in the operation of cafeterias/canteens, dormitories and

from taxation provided they are owned and operated by it as ancillary services. bookstores located within the premises of TIONG SE ACADEMY, INC. are exempt

LIABILITY FOR INTERNAL REVENUE TAXES 1) INCOME TAX

TIONG SE ACADEMY, INC.issubject toincometaxonallits 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

Page 3 of 3 TIONG SE ACADEMY, INC. Date issued CTE No. CA30 -0310-202a JU 9 20

under National Internal Revenue Code of 1997, as amended, on its income derived from should be returned for taxation, unless said revenues are actually, directly and exclusively any of its properties, real or personal, or any activity conducted for profit, which income used for educational purposes.

2) VALUE ADDED TAX/PERCENTAGE TAX If TIONG SE ACADEMY, INC. is engaged in the sale of goods or services in the course of a business pursuit, including transactions incidental thereto, its revenues derived therefrom shall be subject to the 12% VAT, in case the gross receipts from such sales exceed Three Million Pesos (P3,000,000.00)3, or to the 3% percentage tax, if gross receipts do not exceed P3,000,000.00.

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 subject to the 12% V AT pursuant to Sections 106 and 107 of the National Internal Revenue Code of 1997, as amended.

3) WITHHOLDING TAX

TIONG SE ACADEMY, 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 National Internal Revenue Code of 1997, as amended, 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 National Internal Revenue

Code of 1997, as amended, and as implemented by Revenue Regulations No. 2-98, as

amended.

TAXPAYER DUTIES & RESPONSIBILITIES 1)TIONG SE ACADEMY, 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 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 income. Copy of this Certificate of Tax

Exemption shall be attached to the aforementioned Annual Information Return.

2) Under Section 235 of the National Internal Revenue Code of 1997, as amended, any

provision of 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 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 the National

Internal 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 to the activities for which the Association is registered.

(Revenue Memorandum Circular No. [RMC] No. 76-2003).

4) 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. Q