BIR Ruling No. 82-2018

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OFINTERNALREVENUE

Quezon City

Certificate of Tax Exemption Nc. 082-2018

SERTIFICATE OFTAXEXEMPTION

issued to

FEAN SCHOOLFOUNDATIONPHHLIPPINES.INC Cnley Road, Mckinley Hill Town Center, Fort Bonifacio, Taguig City 1630

TIN: SEC Company Reg. No.

as ceifies that the above-named corporation is a non-stock, non-profit corporatior

as N -:1..-:01 ef the National Internal Revenue Code of 1997, as amended. It is exempt from --- r: by actual operation that its primary purpose is one of those enumerated unas- .. only on the following revenues or receipts:

Tition Fees,Enrollment Fees, Admission Test Fees and Miscellaneous Fees Tonations;and Frone derived from operation of cafeterias/canteens and bookstores located

CUNDATION PHILIPPINES,INC.,to be actuallydirectly and exclusieiy in itspremises,ownedandoperatedby KOREAN SCHoO

taed for educational purposes.

nothing follows

surse. tr provisions of applicable BIR rules and regulations and the tax exemprions. niiires ad responsibilities stated in the Terms and Conditions hereto attached and made an inara! ra: hereof. It is liable, however, to all other taxes not enumerated above.

Tii- eerzification shall be valid from the date of issuance until revoked by this Office

i..any provisions of applicable rules and regulations of the BIR, or the terms aud

corti hrein set forth. It shall likewise be revoked if there are material changes in the

enaracir. piirpose or method of operation of the corporation which are inconsistent with the

baa fo is income tax exemption.

Tris Certificate of Tax Exemption is being issued on the basis of the facts and uts as represented and submitted. However, if upon investigation, the BIR ascertains

th ie f are different, then this Certificate shall be considered null and void.

ssthis day ofJAN 3 0 2018

CAESAR R.DULAY Commissioner of Internal Revenue

CELIAC.XING Cuua c.la

Resource Management Groua Deputy Commissioner

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eCeifiwator ofacuarfzaion o the aid incomeand

eEoardSusojution p the ssisot sdoinistration Dn proposed proioers (e

constrretion and/oinprovement ofschool buidings and facities,acguishion

ofecuipmont.booksanethelike.to be funded out of themoney deposirecin

banks or placed ir money markets.on orSefore the15th dayofthe fourth nonth

following the ene of is texabis year Sez.4,Finance Deparment Order No

137-874

PALUE ADDED TAX VAT ON EDUCATIONAL SERVICES. PUTSUR L SCCUO

IOIHOheNRC KPENSCHOLFOUNMATIONPHLIPPIEC.NCSO receips from opyerations es a non-stock.non-profit edueational institution are exerpt from vAt

DILITTORINTRRALLEVENEETAXES

INCOMETAX

Expoa.rever,i is sunjeci to the corresponding inteal revenus taxes impo undr LORANSHOOEDLOHLIPINESNCsbjeertincomc ais inconereteiptsrovenaes nor expressiy exenpted and staisd in the Coruificar or Tax

Korean School Foundation Philippines,Inc Page 3 of 3 Date issued 20 CTE No.8218

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.

2 VALUE ADDED TAX/PERCENTAGE TAX

if KOREAN SCHOOLFOUNDATION PHILIPPINES.INC.is engaged in the sale of goods or services in the course of a business pursuit. inciuding transactions incidental thereto, its revenues

derived therefrom shall be subject to the12% VAT, in case the gross receipts from such sales is

One Million Nine Hundred Nineteen Thousand Five Hundred Pesos (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 Sections 106 and 107 of the NIRC.

3) WITHHOLDING TAX

KOREAN SCHOOL FOUNDATION PHILIPPINES,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, and

as implemented by Revenue Regulations No. 2-98, as armended.

TAXPAYERDUTIES & RESPONSIBILITIES

KOREAN SCHOOL FOUNDATION PHILIPPINES.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-exempi 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

inivoicesfor each sale or transfer of merchandise or for services rendered which are not directly

reiated to the activities for which the Association is registered. (Revenue Memorandum Circular

No.{RMC]No.76-2003

4)Finaily.it is subject io the payment of registration fee of Php 500.00 as prescribed in Section236(B

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

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