bir_ruling BIR Ruling No. 737-2019BIR Ruling No. 737-2019

BIR Ruling No. 737-2019

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No.

0737-2028

CERTIFICATE OFTAXEXEMPTON

issued to

THE U.P.MEDICAL FOUNDATION,INC. U.P. College of Medicinc, 547 Pedro Gil St., Ermita, Manila 1000

SEC Company Reg. No. TIN:

This certifies that the above-named corporation is a non-stock, non-profit corporation and na. Ure 'en by actual operation that its primary purpose falls under Section 30 (F). of-che National Internal Revenue Code (NIRC) of 1997, as amended. It is exempt from INCOME TAX only on the following revenues or receipts:

1. Donations. 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 for three (3) years from the date of issuance unless earlier revoked by this Office for violation of any provisions of applicable rules and regulations of BIR. or the terms and conditions herein set forth.

This Certificate may be renewed upon filing of a subsequent application for revalidation provided under Revenue Memorandum Order (RMO) No. 20-2013. Failure to renew this Certificate shall be deemed a revocation thereof upon the expiration of the three (3)-year period.

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 ofDECI

LROA

CAESARR..DULAY Commissioner of Internal Revenue

K-1-JAC 031131

Y

Page 2 of 3 The U.P. Medical Foundation,Inc. Date issued DEC U 9 2019 CTE No. E737-2019

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

TAX EXEMPTION

1) INCOME TAX.THE U.P.MEDICAL FOUNDATION,INC. is only exempt from the

payment of income tax on revenues and receipts enumerated on the Certificate of Tax

Exemption. Moreover, to be entitled to the tax exemptions enumerated herein, the association/corporation/ organization must continue to meet the requirements set forth

under Revenue Memorandum Order No. 20-2013.

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

THE U.P.MEDICALFOUNDATION.INC.is subject to income tax on all its

income/receipts/revenues not expressiv exempted and state in the Certificate of Tax

Exemption. Moreover, it is subject to the corresponding inter al revenue taxes imposedu

under the National Internal Revenue Code, as amended, on its income derived from any of its

properties, real or personal, or any activity conducted for profit regardless of the disposition

thereof, which income should be returned for taxation.

Likewise, interest income from currency bank deposits and yield or any other monetary benefits from deposit substitute instruments and from trust funds and similar arrangements.

and royalties derived from sources within the Philippines are subject to the twenty percent

(20%) final withholding tax: Provided, however, that interest income derived by it from a depository bank under the expanded foreign currency deposit system shall be subject to fifteen percent (15% final withholding income tax pursuant to Section 27(D)(1) in reiation to Sec. 57(A) both of the National Internal Revenue Code of 1997, as amended.

2) VALUE ADDED TAX/PERCENTAGE TAX

If THE U.P. MEDICAL FOUNDATION, 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)2. 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 107of the National Internal Revenue Code, as amended.

3) WITHHOLDING TAX

THE U.P.MEDICAL FOUNDATION. 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 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 National Internal Revenue Code, as implemented by Revenue Regulations No. 2-98,

as amended.

Page 3 of 3 The U.P. Medical Foundation, Inc. Date issued Ec n e CTE No. 7.37-209

TAXPAYER'S DUTIES & RESPONSIBILITIES

1) THE U.P. MEDICAL FOUNDATION. 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 daring 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, 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 iricentives, and its tax liahilities, if any.

3) Further, it is also required under Section 6(C) in relation to Section 237 of the NIRC 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.

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