BIR Ruling No. 82-2020

REPUBLIC OF-THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No.

SH30-014-2020

CERTIFICATE OFTAXEXEMPTION

issued to

MATER ECCLESIAE SCHOOL (VICTORIA,LAGUNA),INC. Quirino St., Brgy. San Roque, Victoria, Laguna 4011 SEC Company Reg. No. 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

2.Income derived from the operation of cafeterias/canteens, dormitories and bookstores 1.Tuition fees and Other school fees; and located within its premises, owned and operated by MATER ECCLESIAE SCHOOI educational purposes. VICTORIA, LAGUNA), INC., to be actually, directly and exclusively used for

nothing follows.

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

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 certification shall be valid from the date of issuance until revoked by this Office

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. This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this day ofJAN 2 4 202l

Auam

CAESAR R.DULAY Commissioner of Internal Revenue

K-1-JAC 032366

Mater Ecclesiae School (Victoria, Laguna) Inc. CTE No. SH30--014-2020

Page 2 of 3 Date issued JAN Z 4 ZUZU

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

) INCOME TAX. MATER ECCLESIAE SCHOOL (VICTORIA,LAGUNA),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:

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

MATER ECCLESIAE SCHOOL VICTORIA, LAGUNA), 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 institution, are exempt from the 20% final

tax and 15%' 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, 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 information return and duly audited

financial statement together with the following:

(a)Certification from their depository banks 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.

137-87)2.

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

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

SCHOOL (VICTORIA, LAGUNA), INC.'s gross receipts from operations as a non-stock, non

profit educational institution is exempt from VAT. Moreover, revenues derived from assets used in

the operation of cafeterias/canteens, dormitories and bookstores located within the premises of

MATER ECCLESIAE SCHOOL (VICTORIA,LAGUNA),INC. are exempt from taxation

provided they are owned and operated by it as ancillary activities.

LIABILITY FOR INTERNAL REVENUE TAXES

1 INCOME TAX.

1 Republic Act No. 10963 increased the tax rate from 7.5% to 15% effective January 1, 2018.

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

Mater Ecclesiae School (Victoria, Laguna) Page 3 of 3 Inc. CTE No.H30-0142020 Date issued iAN 2 4 2020

MATER ECCLESIAE SCHOOL (VICTORIA,LAGUNA),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 National Internal Revenue Code of 1997, as amended, on its income derived from any of its

for taxation, unless said revenues are actually, directly and exclusively used for educational properties, real or personal, or any activity conducted for profit, which income should be returned

purposes.

2) VALUE ADDED TAX/PERCENTAGE TAX

If MATER ECCLESIAE SCHOOL (VICTORIA,LAGUNA), 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.

MATER ECCLESIAE SCHOOL VICTORIA, LAGUNA), 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 MATER ECCLESIAE SCHOOL VICTORIA,LAGUNA),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 P500.00 as prescribed in Section 236 (B)

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

3 Republic Act No.10963 increased the VAT threshold from P1,919,500.00 to P3,000,000.00 ffective January 1,2018.