BIR Ruling No. 84-2018

REPUBLIC OF T'dE PHILIPPINES DEPARTMENTOF FINANCE BUREAU OF INTERNAX REVENUE Quezon City Certificate of Tax Exemption No. 084-aorB CERTIFICATE OF TAX EXEMPTION issued to OUEZOI\ CITY CTIRISTIAN ACADEMY" II{C. 52M. Cuenco St., Baringay T ourdes, Quezon City 1114 TIN: . SEC Company Reg. No. This certifies that the above-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 30(H) of the National lnternal Revenue Code of 1,997, as amended. It is exempt from INCOME TAX only on the following revenues or receipts: l. Tuition Fees and Nliscellaneous Feesl 2. Income derived from operation of cafeterias/canteens and bookstores located within lts premises, owned and operated by QUEZON CITY CHRISTIAN ACADEMY,INC., to be actually, directly and excluiively used for educational purpose. nothing follows subject to the piovisions 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 he4eof. It is liable, however, to all other taxes not enumerated above. This certification shall be valid fiom the date of issuance until revoked by this Office 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 basis lor its income tax exemption. This Certificate 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. lssued this j day of JAf{ g e0je CAESA,R R. DUI,AY Cominissioner of Internal Revenue K-t a^c.[l

Quezon City Christian Academy, Inc. CTE No. oBLr-aO:i8 Page 2 of3 Date issued 1-fO-2018 TER,MS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION For Non-Stock. Non-Profit Educational Institution TAX EXEMPTION 1) INCOME TAX. OUEZON CITY CHBISTIAN ACADENIY,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 meet the followilig requisites as set forth under Revenue Memoiandum Order (RMO) No 44-2016, to wir: lt is a non-stock, non-profit educational institution; and Its revenues are actually, directly and exclusively used for educational purposes. OUEZON CITY CHRISTIAN dCADEMY.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 iristitution, are exempt fi'orn the 200/o final tax and 1 112% tax on interest incom under the expanded foreign cunency deposit system irnposed under Section2T (D) (1) of the National Intemal Revenue Code of 1997,as amended, subject 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 infonnation return and duly audited financial staternent togethgr with the following: (a)Certification from their depository banks as to the amount of interest income ' eanred from passive investment not subject to the 20o/o final withholding tax and 7 112% tax on interest income underthe expanded foreign currency deposit system imposed by Section 27 (D) (1) of the National Internal Revenue Code of 1991, as amended; (b)Certification of actual utilization of the said income; and (c)Board Resolution by the school administration on p.bposed projects (i.e., cottstruction and/or improvement of school buildings and facilities, acquisition of equipment, books and the like) to be funded out of the money deposited in tranks or placed in money markets, on or before the l5th day ofthe fouith month following the end of its taxable year (Sec. 4, Finance Department Order No. 137-8T). 2) VALUB ADDED TAX (VAT) ON EDUCATIONAL SERWCES. Pursuant to Section NIRC, I 09( l XH) of the gross receipts from VAT. operations as a non-stock, non-profit educational institution are exempt from , LI,A.BILITY FOR INTERNAL RBVENUE TAXES 1) INCOME TAX OUEZON CITY CHRISTIAI\ ACADEIVIY, 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 NIRC, as amended, on its income derived from any of its properties, real or personal, or any activity

Quezon City Christian Academy, Inc. CTE No. Onl+-2OjB Page 3 of3 Date issued t*1Cr."4018 conducted for profit, which income should be retumed for taxation, unless said revenues are actually, directly and exclusively used for educational purposes. 2) VALUE ADDED TAX/PERCENTAGE TAX If OUEZON CITY CIIRISTIAN ACADEMY. INC. is engaged in the sale of goods or services in tlre course of a business pursuit, including transactions incidental thereto, its revenues derived therefrom shall be subject to the l2o/o VAT, in case the gross receipts from such sales is One Milhon Nine Hundred Nineteen Thousand Five Hundred Pesos (P1,919,500.00), or tothe3Yo percentage tax, if gross receipts do not exceed F1,919,500.00. 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 12%VAT pursuant to Sections 106 and 107 ofthe NIRC. 3. WrrrrHoLDrNG.TAX QUEZON CITY CHRISTIAN ACADEIvT.INC. shallbe constituted as withholding agent for tlte 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 theNIRC, as implemented by Revenue Regulations No. 2-98, ai amended, or if it makes income payments to individuals or corporations subject to tlie withholding tax pursuarlt to Section 57 ofthe NIRC, and as implernented by Revenue Regulations No. 2-98, as amended. TAXPAYER DUTIES & RESPONSIBILITIES I ) OUEZON CITY CHRISTIAN ACA-DENIY. INC. is required to file on or before the l5tlr 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 aforementi oned Annual lnformation Return. 2) Under Section 235 of theNational Internal RevenueCode of 1997,asamended, any provision of existing general and special law to the contrary notwithstanding, the books of accounts and other peftinent records of tax-exempt organization or grantees of tax incentives shall be subject to Lxamination 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 arnended, to issue duly registered receipts or sales or commercial invoices for eacli sale or transfer of merchandise or for sewices rendered which are not directly related to the activities for which the Association is registered. (Revenue Memorandum Circular No. [RMCI No. 76-2003). 1) Finally, it is subject to the payment of registration f-ee of PhP 500.00 as prescribed in Section 236(B) of tl-re National Internal Revenue Code of 799'7 , as amended.