BIR Ruling No. 509-2017

REPUBUC OF THF PHILIPPINES

DEPARTMEnt OF FINAnGE BUREAU OF INTERNAI. REVENUE

Quezon City.

Certificate of T'ax Exemption No.

508-17

CERTIFICATE OF TAX EXEMPTION

issued to

SAINT PAULS SCHOOL OF ORMOC FOUNDATION INC Cor. Apitong St. and Lauan St.. Brgy . Punta, Ormoc City, Leyte, Philippines

SEC Company Reg. No. TN:

This certities that the ahove-named corporation is a non-stock, non-profit corporation and has proven by actual operation that its primary purpose is one of those enumerated under Section 301H) ot the National Internal Revenue Code of 1997. as amended. It is exempt from INCOME TAX oniy on the following revenues or receipts:

I. Tuition fees and Other school fees; and 2 Income derived from operation of cafeterias/canteens, dormitories and bookstores

tocated within its premises, owned and operated by SAINT PAUI.S SCHOOL OF ORMOC FOUNDATION, INC., to he actually, directly and exclusively used for educational purposes.

nothing follows

subject to the provisions of applicable BiR rules and regulations and the tax exemptions. tiabiliuies 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 certifieation shall be valid from the date of issuiance until revoked by this Office tor viotation of auy provisions of applicable rutes 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 hasis for its income tax exemption.

This Certiticate of Tax Exemption is being issued on the basis of the facts and 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.

Issued this day ot. NOV 0 7 2017

NaanA

K-I-JA Commissioner ot internul Revenue CAESAR R. DUI.AY 010964

Jrmoc Foundation, Ine. CTE No.EO9-O Date issucd_1i-?-201?

TERMS AND CONDITIONS

OF THE CERTIFICATE OF TAX EXEMPTION

For Non-Stock Non-Profit Educational Institution

nder Section 30(H) of the National Internai Reyenue Code of 1927,as Amended

TAX EXEMPTION

!) INCOME TAX. SAINT PAUL'S SCHOOL OF ORMOC FOUNDATION 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 imeet the following requisites

as set forth under Revenue Memorandum Order (RMO) No 44-2016. to wit:

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

SAINT PAUL'S SCHOOL OF ORMOC FOUNDATION,INC 's interest income from currency

bank deposits and yield from deposit substitute instruments used actually, directiy and exclusively

in pursuance of its purpose as an educational institution. are exempt from the 20% final tax and 7

+/2% tax on interest income umder the expanded foreign currency deposit system imposed under

Section 27 (D) (1) ot the National Internal Revenue Code of 1997. as amended. subject t

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 annual information refurn and duly audited

financiat statenent 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 Interna! 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 tourth month

following the end of its taxable year (Sec. 4, Finance Department Order No)

{37-87}

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES. PurSuant to Section

109(D)(H) of the NIRC, SAINT PAULS SCHOOL OF ORMOC FOUNDATION, INC.'s grOSS

receipts from operations as a non-stock, non-profit educational institution is exempt from VAr

Moreover. revenues derived from assets used in the operation of cafeterias/canteens and hookstores

iocated within the premises of SAINT PAUL'S SCHOOL OF ORMOC FOUNDATION,INC

are exempt from taxation provided they are owned and operated by it as ancillary activities.

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX.

SAINT PAUL'S SCHOOL OF QRMOC 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 subject to the corresponding internal revenue taxes imposed under

Saint Paul's School of Ormoc Foundation, Ine. Page 3 of 3 Date issued_1-7-2017 CTE No. 509-20 17

NIRC. as ainended. 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 revenues are actually, directly and exelusively used for educational purposes.

2) VALUE ADDED TAX

1f SAINT PAULS SCHOOL, OF ORMOC FOUNDATION,INC. is engaged in the sale of goods or services in the course of a business pursuit. including transactions incidental thereto. it. revenues derived theretrom shall he subject to the 12% V Al. in case the gross receipts from sueh sales is One Million Nine Hundred Nineteen Thousand Five Hundred Pesos (f 1.9+9.500.00). or to the 3% percentage tax, if gross receipts do not exceed f 1.919.500.00.

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 t2% VA ! pursuant to Sections l06 and 107 of the NIRC.

3) WITHHOLDING TAX.

SAINT PAUL'S SCHOOL OF ORMOC FOUNDATJON,INC: shall be constituted as withholding agent for the governinent if it acts as an employer and its employees receive compensation ineome subject to the withholding tax under Section 79 (A). Chapter Xill. Title li of the NIRC, as inmplemented by Revenue Regulations No. 2-98. as amended. or if it makes income payments to individuats or corporations subject to the withholding tax pursuant to Section 57 of the NiRC. and as implemented hy Revenue Regulations No. 2-98, as amended.

TAXPAYER DUTIES & RESPONSIBHLITIES

b) SAINT PAUL'S SCHOOL OF ORMOC FOUNDATION INC.is required to file on or before

the 15th day of the fourth month following the end of the accounting period a Protit and koss Statement and Batance Sheet with the Annual Infornation Returu under oath. stating its gross income and expenses incurred during the preceding period and a certificate showing that there has not becn any change in its By-laws. Articles of Ineorporation, 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 atorementioned Annual information Return.

2) Under Section 235 ot the National Internal Revenue Code of 997, as amended. any prov ision of

existing general and special taw to the contrary notwithstanding. the books of accounts and other pertinent records of tax-exempt organization or grantees of tax incentives shali be subiect 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 liabilitics. if any

3) Further, it is also required under Section 6(C) in relation to Section 237 of the National Internal

Revenue (ode of 1997. as amended, to issue duly registered receipts or sates or commereiat invoices for cach sale or transfer of merehandise or for services rendered which are not directly related to the activities for which the Association is registered. (Revenue Memorandum Circutar No. (RMC] No. 76-2003).

4)Finalty. it is subject to the pay ment of registration fee of PhP 500.00 as prescribed in Section

236(B) of the National Internal Revenue Code of 1997. as amended