BIR Ruling No. 413-2018

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Certificate of Tax Exemption No. 413-2018

CERTIFICATE OF TAX EXEMPTION

issued to

NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC. NTC-M Bldg., TESDA Complex, East Service Road SEC Company Reg. No. Western Bicutan, Taguig City TIN

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: This certifies that the above-named corporation is a non-stock, non-profit corporation

h within its premises,"owned "and "operated"by"NORWEGIAN"MARITIME Course Contributions and Donations; FOUNDATION OF THE PHILIPPINES, INC. to be actually, directly and exclusively used for educational purposes. Revenues from Electro Cadet Project, NTC Regutar Cadet and NSA Cadet Income derived from the operation of cafeterias/canteens and bookstores located Enrollment Fee; and

nothing follows

subject to the provisions of applicable BIR rules and regulations and the tax exemptions, integral part hereof. It is liable, however, to all other taxes not enumerated above. liabilities and responsibilities stated in the Terms and Conditions hereto attached and made an

'basis for its income tax exemption. character, purpose or method of operation of the corporation which are inconsistent with the 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 This certification shall be valid from the date of issuance until revoked by this Office

that the facts are different, then this Certificate shall be considered null and void. documents as represented and submitted. However, if upon investigation, the BIR ascertains This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this day of - MAR 0 9 2018

XeAay

K- Commissioner of Internal Revenue CAESAR R. DULAY 014269

NORWEGIAN MARITIME FOUNDATION Page 2 of 3 Date issued 3-9-2018 CTE No. 4-3-2018

under Section 30(H) of the National Internal Revenue Code of 1997, as Amended OF THE CERTIFICATE OF TAX EXEMPTION For Non-Stock, Non-Profit Educational Institution TERMS AND CONDITIONS

TAX EXEMPTION

1) INCOME TAX. NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES INC 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 is exempt from the payment of income tax only on revenues and receipts enumerated on the

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

audited financial statement together with the following: subject to compliance with the conditions that as a tax-exempt educational institution it shalt on an annual basis submit to the Revenue District Office concerned an annual information return and duly 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 /2% tax on interest income under the expanded foreign currency deposit system imposed under Section 27 (D) (1) of the National Internal Revenue Code of 1997, as amended, NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC.'s interest income

of 1997, as amended ea'rned from passive investment not subject to the 20% final withholding tax and 7 1/2% tax on interest income under the expanded foreign currency deposit system imposed by Section 27 (D) (1) of the Nationai Internal Revenue Code (a)Certification from their depository banks as to the amount of interest income

(b)Certification of actual utilization of the said income; and

banks or piaced 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) (c)Board Resolution by the.schoot 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

2)VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES. Pursuant to Section 109(H) as ancillary activities. bookstores |ocated within the premises of NORWEGIAN MARITIME FOUNDATION OF of the NIRC, NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, 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 and THE.PHILIPPINES, INC. are exempt from taxation provided they are owned and operated by it

LIABILITY FOR INTERNAL REVENUE TAXES !) INCOME TAX

Department Order No. 149-95 dated November 24, 1995 amending Department Order No. 137-87

2) VALUE ADDED TAX/PERCENTAGE TAX Page 3.of 3 NORWEGIAN MARITIME FOUNDATION revenues are actually, directly and exclusively used for educational purposes. or any activity conducted for profit, which income should be returned for taxation, unless said Ceriificate 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. income tax on all its income/receipts/revenues not expressly exempted and stated in the NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES. INC. is subiect to CTE No.413-2018 Date issued_3-9-2018

Sections 106 and 107 of the NIRC. (P1,919,500.00), or to the 3% percentage tax, if gross receipts do not exceed P1,919,500.00. 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 thereto, its revenues derived therefrom shall be subject to the !2% VAT, in case the gross receipts from such sales exceed One Million Nine Hundred Nineteen Thousand Five Hundred Pesos the sale of goods or services in the course of a business pursuit, including transactions incidental If NORWEGIAN MARITIME FOUNDATION.OF THE PHILIPPINES, INC. is engaged in

:WITHHOLDING TAX

TAXPAYER DUTIES & RESPONSIBILITIES 57 of the NIRC, and as implemented by Revenue Regulations No. 2-98, as amended. constituted as withholding agent for the government if it acts as an employer and its employees Title HI of the NIRC, as implemented by Revenue Regulations No. 2-98, as amended, or if it makes income payinents to individuals or corporations subject to the withholding tax pursuant to Section NORWEGIAN MARITIME FOUNDATION OF_THE PHILIPPINES, INC. shal be receive compensation income subject to the withholding tax under Section 79 (A), Chapter XIII,

3) Further, it is also required under Section 6(C) in relation to Section 237 of the National Internal 2) Under Section 235 of the National Internal Revenue Code of 1997, as amended, any provision of 1) NORWEGIAN MARITIME FOUNDATION OF THE PHILIPPINES, INC. is required to file No. [RMC] No. 76-2003). 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 Revenue Code of 1997, as amended, to issue duly registered receipts or sales or commercial it has been granted tax exemptions or tax incentives, and its tax liabilities, if any. examination by the BIR for purposes of ascertaining compliance with the conditions under which 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 has not been any change in its By-laws, Articles-of Incorporation, manner of operation and activities attached to the aforementioned Annual Information Return. on or before the 15th day of the fourth month following the end of the accounting period a Profit as well as sources and disposition of income. Copy of this Certificate of Tax Exemption shall be 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

Finally, it is subject to thre payment of registration fee of PhP 500.00 as prescribed in Section 236(B) of the National Internal Revenue Code of 1997, as amended.