BIR Ruling No. 636-2017

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Certificate of Tax Exemption No. 636-2017

CERTIFICATE OF TAX EXEMPTION

issued to COVENANT CHRISTIAN ACADEMY OF RIZAL LAGUNA INC P. Zamora St., Brgy. East Poblacion, Rizal. Laguna SEC Company Reg. No. TIN

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

1. 3 Cafeterias/canteens, dormitories and bookstores sales located within its premises, Tuition and other school related fees; Donation/Grants; and owned and operated by COVENANT CHRISTIAN ACADEMY OF RIZAL LAGUNA INC.

-nothing follows 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 integral part hereof. It is liable, however, to all other taxes not enumerated above.

basis for its income tax exemption. for violation of any provisions of applicable rules 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 This certification shall be valid from the date of issuance until revoked by this Office

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

Issued this day of DEC 1 9 2017

LOM

Commissioner of Internal Revenue CAESAR R. DULAY

011969 K- 1/jrc

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TERMS AND CONDITIONS OF THE 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 EXEMPTION

1) INCOME TAX. COVENANT CHRISTIAN ACADEMY OF RIZAL LAGUNA INC. iS

exempt from the paynent of income tax only on revenues and receipts enumerated on the requisites as set forth under Revenue Memorandum Order (RMO) No 44-2016, to wit: Certificate of Tax Exemption. It is understood that the school must continue to meet the following

ii. Its revenues are actually, directly and exclusively used for educational purposes. 1 It is a non-stock, non-profit educational institution; and

COVENANT CHRISTIAN ACADEMY OF RIZAL LAGUNA INC.'s interest income from currency bank deposits and yield from deposit substitute instruments used actually, directly and exclusively in pursuance of its purpose as an educational institution, are exempt from the 20% final tax and 7 i/2% tax on interest income under the expanded foreign currency deposit system imposed under Section 27 (D) (1) of the Nationai Internal Revenue Code of 1997, as amended. suhject to 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 return and duly audited financial statement together with the following:

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

of 1997, as amended: and 7 1/2% tax on interest income under the expanded foreign currency deposit system imposed by Section 27 (D) (1) of the National Internal Revenue Code earned from passive investment not subject to the 20% final withhoiding tax

(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 fourth month following the end of its taxable year (Sec. 4. Finance Department Order No. 137-87)

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES. Pursuant to Section gross receipts from operations as a non-stock, non-profit educational institution are exempt from VAT. 109(H) of the NIRC.COVENANT CHRISTIAN ACADEMY OF RIZAL LAGUNA INC.'s

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

on all its income/receipts/revenues not expressly exempted and stated in the Certificate of Tax COVENANT CHRISTIAN ACADEMY OF RIZAL LAGUNA INC. is subject to income tax

Department Order No. 149-95 dated November 24, 1995 amending Department Order No. t 37-87 IE

COVENANT CHRISTIAN ACADEMY OF RIZAL LAGU'NA INC. Page 3 of 3 Date issued_12-19-2017 CTE No. 636-20 17

NIRC, 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 revenues are actually. directly and exclusively used for educational purposes. Exemption. Moreover, it is subject to the corresponding internal revenue taxes imposed under

2) VALUE ADDED TAX

lf COVENANT CHRISTIAN ACADEMY OF RIZAL LAGUNA INC. is engaged in the sale of goods or services in the course of a business pursuit, including transactions incidental thereto. in general. it shall be liable for VAT on the revenues derived therefrom.

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% VAT pursuant to Sections 106 and 107 of the NIRC.

4 WITHHOLDING TAX

the NIRC. as implemented by Revenue Regulations No. 2-98, as amended, or if it makes income NIRC, and as implemented by Revenue Regulations No. 2-98, as amended. withholding agent for the government if it acts as an cmployer and its employees receive payments to individuals or corporations subject to the withholding tax pursuant to Section 57 of the COVENANT CHRISTIAN ACADEMY OF RIZAL LAGUNA INC. shall be constituted as compensation income subject to the withnolding tax under Section 79 (A), Chapter XI11, Title II of

TAXPAYER DUTIES & RESPONSIBILITIES

( COVENANT CHRISTIAN ACADEMY'OF RIZAL LAGUNA INC. is required to file on or

income and expenses incurred during the preceding period and a certificate showing that there has attached to the aforementioned Annual Information Return. 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 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

2) Under Section 235 of the National Internal Revenue Code of 1997, as amended. any provision of it has been granted tax exemptions or tax incentives, and its tax liabilities, if any. 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

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

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