BIR Ruling No. 501-2017

REPUBLIC OF THE PHILIPPINES

DEPaRTMENT oE FInANCF BUREAU OF IN'TERNAL REVENUE

Quezon City

Certificate of Tax Exemption No.

X-

CERTIFICATE OF TAX EXEMPTION

issued to

ATENEO DE MANILA UNIVERSITY, INC.

Katipunan Rd.. Lovola Heishts. Quezon City 1108 SEC Company Reg. No. TIN

INCOME TAX only on the following revenues or receipts: and has proven by actual operation that its primary Section 30 (H) of the National Internal Revenue Code of 1997. as amended. It is exempt from This certifies that the above-namcd corporation is a non-stock. non-profit corporation y purpose is one of those enumerated under

2 Tuition Fees & Other School Related Fees; and Income derived from the operation of cafeterias/canteens and bookstores located within its premises, owned and operated by Ateneo De Manila University, Inc., to'bc actually, directly and exclusively used for educational purposes.

nothing follow

subject to the provisions of applicable BiR rules and regulations and the tax excmptions. integral part hereof. It is liable. however. to all other taxes not enumerated above. liabilities and responsibilities stated in the T'erms and Conditions hereto attached and made an

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 for violation ot any provisions of applicable rules and regulations of the BIR. or the terms and 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 Certificatc of Tax Exemption is being issued on the basis of the facts and

Issued this. day of

Commissioner of Internal Revenuc CAESAR R. DULAY 0 108 33

-K-I-IMAT

ATENEO DE MANILA UNIYERSITY. INC. Date issued .- CTE NO.. 0--C7 C

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

TAX EXEMPTION

I) INCOME TAX

the school must continuc to meet the following requisites as set forth under Revenue Memorandum Order (RMO) No 44-2016. to wit: ATENEO DE MANILA UNIVERSITY, INC. is exempt from the payment of incomc tax only on revenues and reccipts enumerated on the Certificate of Tax Exemption. it is understood that

a) It is a non-stock. non-profit educational institution: and b} Its revenues are actually, directiy and exclusively used for educational purposes

the National Internal Revenue Code of 1997. as amended, subject to compliance with the conditions Office concerned an annual information return and duly audited financial statement together with ATENEO DE MANILA UNIVERSITY, INC.'s interest income fron currency bank deposits and yield from deposit substitute instruments used actually. directly and exclusively in pursuance of its purpose as an educational institution, are exeinpt froin the 20% final tax and 7 1/2% tax on interest that as a tax-exempt educational institution it shall on an annual basis submit to the Revenue District income under the expanded foreign currency deposit system imposed under Scction 27 (D) (1) of the following

a} Certification from their depository banks as to the amount of interest income and 7 1/2% tax on interest income under the expanded foreign currency deposit earncd from passive investment not subject to the 20% final withholding tax system imposed hy Scction 27 (D) (I) of the National Internal Revenue Code of 1997. as amended:

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

c) Roard Resolution by the school administration on proposed projects (i.e.. construction and/or improvement of school buildings and facilities. acquisition banks or placed in money markets. on or before the 15th day of the fourth month following the end of its taxahle year (Sec. 4. Finance Department Order of cquipment. books and the like) to be funded out of the money deposited in No. 137-87)'.

2) VALUE ADDED TAX (VAT)ON EDUCATIONAL SERVICES

educational institution are exempt from V AT. Pursuant to Section 109(H) of the National Internal Revenue Code of 1997. as amended, ATENEO DE MANILA UNIVERSITY, INC.'s groSs receipts from operations as a non-stock. non-profit

LIABILITY FOR INTERNAL REVENUE TAXES I) INCOME TAX

properties. real or personal. or any activity conducted for profit. which income should he returned income/receipts/revenues not expressly exempted and stated in the Certificate of Tax Exemption. Morcover, it is subject to the corresponding internal revenue taxes imposed under the National Internal Revenue Code of 1997. as amended. on its income derived from any of its ATENEO DE MANILA UNIVERSITY, INC. is subject to income tax on all its

' Deparrment Order No. 149-95 dated November 24. 1995 amending Department Order No. +37-87

PAGE 70'3

ATENEO DE MANILA UNIVERSITY, ING Date issued 1mm20 (TE No.-501-2017

for taxation. unless said revenues are actually, directiy and exclusively used for educational purposes.

2) VALUE ADDED TAX (VAT)/PERCENTAGF TAX

the three percent (3%c) percentage tax. if gross receipts do not exceed One Mitlion Ninc Hundred Nineteen Thousand Fivc Hundred Pesos (P1,9+9.500.00). therefrom shall be subject to the twelve percent (12%) VAT. in case the gross receipts trom such Sales is One Million Nine Hundred Nineteen Thousand Five Hundred Pesos (P1.919.500.00). or to If ATENEO DE MANILA UNIVERSITY, INC. is engaged in thc salc of goods or scrvices in the course of a business pursuit. including transactions incidental thereto. its revenues derived

Notwithstanding that it is a non-stock. non-profit corporation. its purchase of goods or properties or services and importation of goods shall nevertheless he subject to the twelve percent (12%) VAT pursuant to Sections 106 and 107 of the National Internal Revenue Code of 1997. as anended.

3) WITHHOLDING TAX

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 withholding tax under Section 79 (A). Chapter X!11, Title II of the National Internal Revenue Code of 1997. as amended, as implemented by Revenuc Regulations No. 2-98. as amended, or if it makes ATENEO DE MANILA UNIVERSITY, INC. shall be constituted as withholding agent tor the Regulations No. 2-98. as amended. government if it acts as an employer and its employees receive compensation income subject to the

TAXPAYER DUTIES & RESPONSIBILITIES

I} ATENEO DE MANILA UNIVERSITY, INC. is required to file on or before the 15th day of the aforementioned Annual Information Return. Shect 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 disposition of income. Copy of this Certificate of Tax Exemption shall be attached to the fourth month following the end of the accounting period a Profit and Loss Statement and Balance in its By-laws. Articles of incorporation. inanner of operation and activities as well as sources and

2) Under Section 235 of the National Internal Revenue Code of 1997. as amended. any provision of it has heen granted tax exemptions or tax incentives. and its tax liabilities. if any. existing gencral 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 cxamination by the BiR for purposes ot ascertaining compliance with the conditions under which

3) Further. it is also required under Section 6(C) in relation to Section 237 of the National Internal invoices for each sale or transfer of merchandise or for services rendered which are not directy related to the activities for which the Association is registered. (Revenue Memorandun Circular Revenuc Code of 1997. as amended. to issue duly registered rcceipts or sales or commercial 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.

L-K-I-LMAT

PAGE ROF 3