BIR Ruling No. 404-2021

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

3 Certificate of Tax Exemption No. 104-2a21 NOY 3..2021

CERTIFICATE OF TAX EXEMPTION

issued to

MOTHER OF LIFE CENTER, INC. 123 Susano Road San Agustin Novaliches, Quezon City SEC Company Reg. No. TIN.

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 and Miscellaneous Fees; and 2. Income derived from the operation of cafeterias/canteens, dormitories and bookstores Iocated within its premises, owned and operated MOTHER OF LIFE CENTER. INC.. to be actually, directly and exclusively used for educational purposes.

rothing follows

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

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

conditions herein set forth. It shall likewise be revoked if there are materia! changes in the character, income tax exemption. violation of any provisions of applicable rules and regulations of the BIR, or the terms and purpose or method of operation of the corporation which are inconsistent with the basis for its

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 of NOV j 3 2t2T

1ewaMy

K-I Commissioner of Internal Revenue CAESAR R. DULAY 046742

MOTHER OF LIFE CEN'TER, INC. Page 2 of 3 CTE No. SH30 Date issued NOV 3 2021 IC&20t

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

under Section 30(H) of the National Internal Revenue Code of 1997, as Amended For Non-Stock, Non-Profit Educational Institution

TAX EXEMPTION

1) INCOME TAX.MOTHER OF LIFE CENTER,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. 1. Its revenues are actually, directly and exclusively used for educational purposes. It is a non-stock, non-profit educational institution; and

MOTHER OF LIFE CENTER, INC.'s interest income from currency bank deposits and yield from deposit substitute instruments used actually, directly and exclusively in

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: pursuance of its purpose as an educational institution, are exempt from the 20% final tax and 15%' 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

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

b C or placed in money markets, on or before the 1 5th day of the fourth month following 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. Certification of actual utilization of the said income; and 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 the end of its taxable year (Sec. 4, Finance Department Order No. 137-87)2. Board Resolution by the school administration on proposed projects (i.e.,

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES. Pursuant to Section LIFE CENTER, INC.'s, gross receipts from operations as a non-stock, non-profit educational institution are exempt from VAT. Moreover, revenues derived from assets used 109(1)(H) of the National Internal Revenue Code of 1997, as amended, MOTHER OF

in the operation of cafeterias/canteens, dormitories and bookstores located within the premises of MOTHER OF LIFE CENTER, INC. are exempt from taxation provided they are owned and operated by it as ancillary services.

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

MOTHER OF LIFE CENTER,INC. is subject to income tax on all its

any of its properties, real or personal, or any activity conducted for profit, which income should be returned for taxation, unless said revenues are actuaily, directly and exclusively 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 income/receipts/revenues not expressly exempted and stated in the Certificate of Tax

used for educational purposes.

2 Deparment Order No.149-95 datedNovember 24 1995 amending Deparmen Order No. 137-87 Republic Act No. 10963 increased the tax rate from 7.5% to 15% effective Jan. 1, 201 K

MOTHER OF LIFE CENTER, INC. Page 3 of 3 CTE No. SH2Q'13; C : - 202 1 Date issued NOV 0-3 2021

2) VALUE ADDED TAX/PERCENTAGE TAX

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. course of a business pursuit, including transactions incidental thereto, its revenues derived therefrom shall be subject to the +2% VAT, in case the gross receipts from such sales If MOTHER OF LIFE CENTER. INC. is engaged in the sale of goods or services in the

properties, services and importation of goods shall nevertheless be subject to the 12% VAT pursuant to Sections 106, 108 and 107 of the National Internal Revenue Code of 1997, as amended. Notwithstanding that it is a non-stock, non-profit corporation, its purchase of goods or

3) WITHHOLDING TAX

government if it acts as an employer and its employees receive compensation income MOTHER OF LIFE CENTER, INC. shall be constituted as withholding agent for the

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) The honoraria/allowances given to members of the Board of Trustees must be reasonable and

subject to liquidation (DOF Opinion No. 005-2019).

2) Required to file on or before the 15th day of the fourth month following the end of the Copy of this Certificate of Tax Exemption shall be attached to the aforementioned Annual 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 accounting period a Profit and Loss Statement and Balance Sheet with the Annual Information

Information Return.

3) 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

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. pertinent records of tax-exempt organization or grantees of tax incentives shall be subject to

4) Further, it is also required under Section 6(C) in relation to Section 237 of the National Internal No. [RMC] No. 76-2003). invoices for 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 Revenue Code of 1997, as amended, to issue duly registered receipts or sales or commercial

5)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, 2018