BIR Ruling No. 439-2017

BUREAU OF INTFRNAL REVENUE REPUHLCOTHEPHHLIPPINES DFPARIMINTOY TINANGT Quezon City

Certificate of Tax Exemption No. 439- 17

CERTIFICATE OF TAX EXEMPTION

issued to

Estrella Street corner Amapola Street, Bel-Air. Makati City MARTHA'S VINEYARD, INC SEC Company Reg. No. TIN:

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

I. Donations; and 2. Membership Fees/dues. nothing follows

subject to thc provisions of applicable BIR rules and regulations and the tax exemptions. Hiabitities 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.

earlier revoked by this Office for violation of any provisions of applicable rules and regulations of BIR, or the terms and conditions herein set forth. This certification shall be valid for three (3) years from the date of issuance unless

period. Certificate shall be deemed a revocation thereof upon the expiration of the three (3)-year provided under Revenue Memorandum Order (RM0) No. 20-2013. Failure to renew this This Certificate may be renewed upon filing of a subsequent application for revalidation

documents as represented and submitted. However. if upon investigation. the BIR asccrtains 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 : 201

Commissioner of Intemal Revenuc CAESAR R. DULAY

K-1VDPM14 Martha's Y Tneyard, inc. Cu

Deputy Commissioner CeLIA C' KING

MARTHA 'S VINEYARD, INC. Page 2 of 3 Date issued CTE No. +3-017

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

TAX EXEMPTION 1) INCOME TAX. MARTHA'S VINEYARD, INC. is on!y exempt from the payment of income tax on revenues and receipts enumerated on the Certificate of Tax Exemption association/corporation/ organization must continue to mect the requirements set forth under Revenue Memorandum Order No. 20-2013. Moreover, to be entitled to the tax exemptionsenumerated herein. the

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

MARTHA'S VINEYARD, INC. is subject to income tax on all its income/receipts/revenues not cxpressly exempted and stated in the Certificate of Tax Exemption. Moreover, it is subject to the corresponding internal revenue taxes imposed under the NIRC on its income derived from any of its properties, real or personal. or any activity conducted for profit regardless of the disposition thereof. which income should be returned for taxation.

Likewise, interest income from currency bank deposits and yield or any other monetary benefits from deposit substitute instruments and from trust funds and similar arrangements. and royalties derived from sources within the Philippines are subject to the twenty percent (20%) final withholding tax: Provided, however, that interest income derived by it from a depository bank under the expanded foreign currency deposit system shall be subject to seven and one-half percent (7-1/2%) final withholding income tax pursuant to Section 27(D)(1) in relation to Sec. 57(A) both of the NIRC.

2) VALUE ADDED TAX

course of a business pursuit, including transactions incidental thereto, in general, it shall be liable for VAT on the revenues derived therefrom. If MARTHA'S VINEYARD, INC. is engaged in the sale of goods or services in the

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

3) WITHHOLDING TAX

MARTHA'S VINEYARD, INC. shall be constituted as withholding agent for the government if it acts as an employer and its employees receive compensation income subject to the withholding tax under Section 79 (A), Chapter XHII, Title II of the NIRC, as implemented by Revenue Regulations No. 2-98, as amended, or if it makes income payments to individuals or corporations subject to the withholding tax pursuant to Section 57 of the NIRC, as implemented by Revcnue Regulations No. 2-98, as amended.

TAXPAYER'S DUTIES & RESPONSIBHLITIES

1) MARTHA'S VINEYARD, 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 Statement and

MARTHA 'S VINEYARD, INC Page 3 of 3 Date issued 9.6-2017 CTE No. 439-2017

Balance Sheet with the Annual Information Return under oath. stating its gross income and been any change in its By-laws. Articles of Incorporation. manner of operation and expenses incurred during the preceding period and a certificate showing that there has not Exemption shall be attached to the aforementioned Annual Information Return. activities as well as sources and disposition of income. Copy of this Certificate of Tax

2) Under Section 235 of the NIRC. any provision of existing general and special Iaw to the organization or grantees of tax incentives 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 incentives, and its tax liabilities. if any. contrary notwithstanding. the books of accounts and other pertinent records of tax-exempt

3) Further, it is also required under Section 6(C) in relation to Section 237 of the NIRC to issuc duly registered receipts or sales or commercial invoices for cach sale or transfer of 2003} which the Association is registered. (Revenue Memorandum Circular No. [RMC] No. 76 merchandise or for services rendered which are not directly related to the activities for

4) Finally. it is subject to the payment of registration fee of PhP 500.00 as prescribed in Section 236(B) of the NIRC.