BIR Ruling No. 348-2021

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMFNT OF FINANCE Quezon City.

Certificate of Tax Exemption No. $43- 3 48- 28 21

CERTIFICATE OF TAX EXEMPTION

issued to

No. 70 Timothy Street, Multinational Village, Paranaque City MADRE MARIA PIA NOTARI SCHOOL, INC. SEC Company Reg. No. TIN:

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 and

I. Tuition and Miscellaneous Fees; and 2. Income derived from the operation of cafeterias/canteens, dormitories and bookstores located within its premises, owned and operated MADRE MARIA PIA NOTAR SCHOOL, INC., to be actually, directly and exclusively used for educational purposes.

Eothing 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 from the date of issuance until revoked by this Office for

conditions herein set forth. It shall likewise be revoked if there are material changes in the character, 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 income tax exemption.

This Certificate of Tax Exemption is heing issued on the basis of the facts and documents

different, then this Certificate shall be considered null and void. as represented and submitted. However, if upon investigation, the BIR ascertains that the facts are

Issued this day of OCT 0 4 202}

1880M

Commissioner of Internal Revenue CAESAR R. DULAY 045838 K-1-MDT

MADRE MARIA PIA NOTARI SCHOOL, INC. Page 2 of 3. CTENo. SH3t.- 3 : 8 - 2 0 2 E Date issuedOC4202U

TERMS AND CONDITIONS OF THECERTIFICATE OF TAX EXEMPTION

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

TAX EXEMPTION

1) INCOME TAX. MADRE MARIA PIA NOTARI SCHOOL, 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:

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

audited financial statement together with the following: to 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 MADRE MARIA PIA NOTARI SCHOOL,INC.'s interest income from currency bank deposits and yield from deposit substitute instruments used actually, directly and 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 exciusively in pursuance of its purpose as an educational institution, are exempt from the

b C a or placed in money markets, on or before the 1 5th day of the fourth month following Certification from their depository bank as to the amount of interest income earned 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. Board Resolution by the school administration on proposed projects (i.e.. 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. from passive investment not subject to the 20% final withholding tax and 15% tax Certification of actual utilization of the said income; and construction and/or improvement of school buildings and facilities, acquisition of

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES. Pursuant to Section 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, MADRE MARIA PIA NOTARI SCHOOL, INC.'s gross receipts from operations as a non-stock, non-profit

premises of MADRE MARIA PIA NOTARI SCHOOL, INC. are exempt from taxation provided they are owned and operated by it as ancillary services. in the operation of cafeterias/canteens, dormitories and bookstores located within the

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX MADRE MARIA PIA NOTARI SCHOOL, 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 properties, real or personal, or any activity conducted for profit, which income Should be'returned for taxation, untess said revenues are actually, directly and exclusiyely used for educational purposes.

1 Republic Act No. 10963 increased the tax rate from 7.5% lo 15% effective Jan. 2 Department Order No. 149-95 dated November 24, 1995 arntnding Depart Order No. 137-87 .2018

MADRE MARIA PIA NOTARI SCHOOL, INC. Page 3 of 3 CTE No. Date issued _ i 21 54 11

2) VALUE ADDED TAX/PERCENTAGE TAX If MADRE MARIA PIA NOTARI SCHOOL 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 F3,009,000.00.

Notwithstanding that it is a non-stock, non-profit corporation, its purchase of goods or 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

3)WITHHOLDING TAX MADRE MARIA PIA NOTARI SCHOOL, 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 rakes 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 impiemented 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

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.

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 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.

4) Further, it is aiso required under Section 6(C) in relation to Section 237 of the Nationai Internal

Revenue Code of 1997, as amended, to issue dufy registered receipts or sales or commercial invoices for each sale or transfer of mcrchandise 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).

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.

3 Republic Act No. 10963 inc he VAT threshold from P1,919,500.00 to P3,000. n. 1, 2018