BIR Ruling No. 617-2020

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OFINTERNAL REVENUE Quezon City

Section 30, National Internal Revenue

Code of 1997

OT-0617-2020

OCT 2 8 Z020

Brent International School, Baguio, Inc. Brent Road, Baguio City 2600

Gentlemen: Attention: Dr. Celeste R. Coronado School Principal

School, Baguio, Inc. be exempt from the payment of taxes due on the proceeds from the Christmas bazaar held by Brent International School, Baguio, Inc. last November 16 and 17, 2019 at Brent Memorial Gymnasium. This refers to your letter dated October 2, 2019, requesting that Brent International

International School, Baguio, Inc. is subject 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 the National Internal Revenue Code (NIRC) of 1997, as amended, on its income derived from any of its properties, real or personal, or any activity conducted for profit, which income should be returned for taxation, unless said reversues are actually, directly and exclusively used for educational purposes. Please be informed that under Certificate of Tax Exemption No. 147-17, Brent

it shall be liable for 12% value-added tax (VAT) on the revenues derived therefrom if the gross receipts from such sales exceed Three Million Pesos (P3,000,000.00)', or to 3% percentage tax, services in the course of a business pursuit, including transactions incidental thereto, in general, if gross receipts do not exceed P3,000,000.00. Further, if Brent International School, Baguio, Inc. is engaged in the sale of goods or

shall nevertheless be subject to the 12% VAT pursuant to Sections 106 and 107 of the NIRC of] 1997, notwithstanding that it is a non-stock, non-profit corporation. Moreover, its purchase of goods or properties or services and importation of goods

the aforesaid Christmas bazaar were not shown to have been actually, directly and exclusively used for educational purposes and are therefore not exempted from income tax and VAT. Considering the above, we cannot grant your request since the revenues derived from

Please be guided accordingly.

Very truly yours,

KI-RPT K1-FR-19-1618 Commissioner of Internal Revenue Aeesandn CAESAR R.DULAY 037312

1 Republic Act No. 10963 increased the VAT threshold from P1,919,500.00 to P3,000,000.00 effective Jan. 1, 2018