BIR Ruling No. 396-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No. SH30-0396-2020

CERTIFICATE OF TAX EXEMPTION

issued to

CONPEREY INTEGRATED LEARNING SCHOOL,INC.

Caticlan, Malay, Aklan 5608

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 Internal Revenue Code of 1997, as amended. It is exempt from INCOME

TAX only on the following revenues or receipts:

1 Tuition, Registration and Miscellaneous Fees; and

2. Income derived from the operation of cafeterias/canteens, dormitories and bookstores

Iocated within its premises, owned and operated by CONPEREY INTEGRATED

LEARNING SCHOOL, INC., to be actually, directly and exclusively used for

educational purposes.

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.

This certification shall be valid from 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 for 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.

Issued this day ofJUL1 7 2020

1asmru

CAESAR R.DULAY

Commissioner of Internal Revenue

K-1/spf1 90032 035786 O

Conperey Integrated Learning School, Inc. Page 2 of 3 Date issued CTE No. 3 -1'1 8b5g-202 a 1

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. CONPEREY INTEGRATED LEARNING SCHOOL,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

following requisites as set forth under Revenue Memorandum Order (RMO) No 44-2016, to

wit:

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

currency bank deposits and yield from deposit substitute instruments used actually, directly and CONPEREY INTEGRATED LEARNING SCHOOL, INC.'s interest income from

exclusively in pursuance of its purpose as an educational institution, are exempt from the 20%

final tax and i5%' tax under the expanded foreign currency deposit system imposed under

Section 27(D)(1) of the National Internal Revenue Code of 1997, as amended, subject to

compliance with the conditions that as a tax-exempt 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 bank as to the amount of interest income earned from passive investment not subject to the 20% final withholding tax and

15% tax on interest income under the expanded foreign currency deposit system imposed by Section 27(D)(1) of the National Internal Revenue Code of 1997, as

amended.

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 15th day of the fourth month

following the end of its taxable year (Sec. 4, Finance Department Order No. 137-

872

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES.Pursuant to Section

109(1)(H) of the National Internal Revenue Code of 1997, as amended, CONPEREY

INTEGRATED LEARNING SCHOOL, INC.'s gross receipts from operations as a non-

stock, non-profit educational institution are exempt from VAT. Moreover, revenues derived

from assets used in the operation of cafeterias/canteens, dormitories and bookstores located

within the premises of CONPEREY INTEGRATED LEARNING SCHOOL, INC.are

exempt from taxation provided they are owned and operated by it as ancillary services.

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

CONPEREY INTEGRATED LEARNING SCHOOL,INC. is subject to income tax on all

its income/receipts/revenues not expressly exempted and stated in the Certificate of Tax

Republic Act No. 10963 increased the tax rate from 7.5% to 15%effctive Jan. 1,2018 Q

Conperey Integrated Learning School, Inc. Page 3 of 3 CTE No. Date issued SH30-395-2020 T 17 2020

National Internal Revenue Code of 1997, as amended, on its income derived from any of its Exemption. Moreover, it is subject to the corresponding internal revenue taxes imposed under returned for taxation, unless said revenues are actually, directly and exclusively used for properties, real or personal, or any activity conducted for profit, which income should be educational purposes.

2) VALUE ADDED TAX/PERCENTAGE TAX If CONPEREY INTEGRATED LEARNING SCHOOL,INC. is engaged in the sale of goods or services in the course of a business pursuit, including transactions incidental thereto, its revenues derived therefrom shall be subject to the 12% VAT, in case the gross receipts from such sales exceed Three Million Pesos (P3.000.000.00)3, or to the 3% percentage tax, if gross receipts do not exceed P3,000,000.00.

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 of the National Internal Revenue Code of 1997, as amended.

3)WITHHOLDING TAX

CONPEREY INTEGRATED LEARNING_SCHOOL, 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 XIII, Title

II of the National Internal Revenue Code of 1997, as amended, 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 National Internal

Revenue Code of 1997, as amended, and as implemented by Revenue Regulations No. 2-98, as

amended.

TAXPAYER DUTIES & RESPONSIBILITIES 1) CONPEREY INTEGRATED LEARNING SCHOOL,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 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 aforementioned Annual Information Return.

2)Under Section 235 of the National Internal Revenue Code of 1997, as amended, any provision

of 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 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 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.

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