BIR Ruling No. 635-2019

REPUFOY THE PHILIPRINES

DERNMT OF FINANCE BUREAU : 3F TERNAL REVENUE

Qnzon City

Certificate of Tax Exemption No.

t

CERTFICATE OF TAX EXEMPTION

issued to

ING FOUNDATION PHILIPPINES, INC

21st Floor, Tower One. Ayala Triangle.

SEC Compary Reg. No. Ayal. Avenue, Makati City TIN:

This cerrifies that the above-nar:ea entity is a non-stock, non-profit corporation an has oroven by atual operation that its prinrary purpose is one of those enumerated under Section 30 (E) of the National Internal Revenu:. Code of 1 997. as amended. It is exempt from INCOME TAx oniy .n the following revenues o. .eceipts:

L Donations.

nothing foilows

subject to the provisions of applicatie BIR rules and regulations and the tax exenptions. tiabiiities and responsibilities stated in ine Terms and Conditions hereto attached and made ar integral pait hereof. It is liable, howes'er, i all cther taxes not erumerated above.

Tnis cerrification shall be vala for three (3) years from the date of issuance untii et okei1 oy this Office for violation of ary provisicns of applicable rules and regulations of the Bik, or the terms and conditions herei: set forth.

This Certificate may be renewec upon filing of a subsequent appiication for revalidatior. prev:ded under Revenue Memorandur.n Otier (RMO) No. 20-2013. Failure to renew this Certiticate shall be deemed a revocatior thereof upon the expiration of the three (3)-year

period.

Ihis Certificate of Tax Exenatior is being issued on the basis of the facts and d..uenis as represented and submi tra. However, if upon investigation, the BIR ascertains tha: tre facis are different, then this Certif cara shall be considered null and void.

Issued this. -. day of

AaRoA

CAESAR R DULAY Commissioner of Internal Revenue 029834

A1-fR-18-1122 KI-JESS

E-2213 IG FCLNDATICN PHILIPPINES, INC. Date issued: CTE NO 135-

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

TAX EXEMPTION

L : INCOME TAX.

ING FOUNDATION PHILIPPINES. NC. is exempt from the payment of income tax only on revenues and receipts enurneratci on the Certificate of Tax Exemption. Morcover. to be entitled to the tax exemptioas erumerated herein, the association, corporation or organization must continue to meer tre requirements set forth under Revenue Memorandun Order No. 20-2013.

LIABILITYFOR INTERNAL REVENUE TAXES

1 HNCOME TAX

KGFOUNDATION PHILIPPINESINC. is subject to income tax on ail is incomerreceipts/revenues not expressly exempted and stated in the Certificate of Tax Exeniption. Moreover, it is subject to the coiresponding internal revenue taxes imposed uder the National Internal Revente Code of 1997, as amended, on its income derived from any of its properties, real or personai, or any activity conducted for profit regardless of the reeeived by the foundation is subject to taxaticn. disposition thereof, which income shouid be returned for taxation. Thus, dividend incorne

tc, Sec. '57(A) both of the National Internal Revenue Code of 1997, as amended. Likewise, interest income from currerisy cank deposits and yield or any other monetary bereiits from deposit substitute insiruments and from trust funds and similar arrangements: and royalties derived from sources withir. the Philippines are subject to the twenty percent (20%) final withholding tax: Pro vided. lisvever, that interest incone derived by it from a depositery bank under the expaudea ioreigr currency deposit system shall be subject to Nfteen Fercent (15%l) final withholding income tax pursuant to Section 27(D)(1) in relation

2) WALUE ADDED TAX/PERCENTAGE TAX

It IG FOUNDATION PHILIPPINES, INC.is engaged in the sale of goods or services ir: the course of a business pursuit. including transactions incidental thereto, its revenues receipts no not exceed P3,000,000.00. derrved therefrom shall be subject t the 12% VAT, in case the gross receipts from such sales exeeed Three Million Pesos (P3.009.000.00)2, or to the 3% percentage tax, if gross

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 subiect to the 12% Value-adaed tax pursuant to Sections 1ce and 107 of the National Internal Revenue Codel of 1997, as amended.

: * 1r67n from 7.59 te 15%: effect:ve January 1,2018 Rep :l.: At N.. 10963 increased tne VAT thresholc . 0:r. P,315,330,00 to #3.000,000.03 effective January 1, 2018.

IG FCLNDATION PHIUPPINES,ING 3 f 3 CTE D Date issued:

3: WITHHOLDING TAX

Subject to the withhoiding iax under Section 79 () Chapter XIII, Title II of theNational the withholding tax pursuant to Seetion 57 of the National Internal Revenue Code of 1997.- the govermment if it acts as an empibyer ard its employees receive compensation income Internal Revenue Code of 1 997, as amenaed. as inplemented by Revenue Regulations No. INK FOUNDATION PHILIPPINES. NG. shall be constituted as withholding agent for -93. as amended, or if it makes ineorne payments to individuals or corporations subject to

as arrended, as implemented by Reverue Regulations No. 2-98, as amended.

TAXPAYER'S DUTIES & RESPOASIBILITIES

1 ING FOUNDATION PHILIPPINES,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 Stateinent ara Baiance Sheet with the Annual Intermation Returm under oath, stating its gross income and expenses incurred.during the preceding period and a certificate showing that there has not teen any change in its By-laws. Articies of Incorporation, manner of operation and activities as well as sources and disposition of income. Copy of this Certificate of Tax Exernption shall be attached to the aforementioned Annual Information Return.

2; Under Section 235 of the National Internai Revenue Code of 1997, as amended. any

provision of existing general and speciai iaw to the contrary notwithstanding, the books of aecounts and other pertinent records of tax-exempt organization or grantees of tax inceri es 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 incer tis es, and its tax liabilities. if any .

3: Furdker. it is also required under &eetion: 6(C) in relation to Section 237 of the National Iaterral Revenue Code of 1997. as aimended, to issue duly registered receipts or sales or commercial invoices for each sale cr iransfer of merchandise or for services rendered which

are not directly related to the activities for which the Corporation is registered. (Revenue Memorandum Circular No. [RMC] No. 76-2003).

j Finally. it is subject to the payment cf registration fee of PhP500.00 as prescribed in

See:ion 236(B) of the National Internai Revenue Code of 1997, as amended