BIR Ruling No. 408-2022

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Certificate of Tax Exemption No.

S30H- 4 0 8 - 2 0 2 2

CERTIFICATE OF TAX EXEMPTION

issued to

HOME ORIENTED PRIME EDUCATION CHRISTIAN

Peliz Loy Centrum Bldg. KM.5. Balili, La Trinidad, Benguet 2601 SEC Company Reg. No. ACADEMY,INC. TIN:

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

1. Tuition and matriculation fees; 2. 3. Student activities and laboratory fees; and Income derived from the operation of cafeterias/canteens, dormitories and bookstores located within its premises, owned and operated by HOME ORIENTED PRIME EDUCATION CHRISTIAN ACADEMY,INC. to be actually, directly and exclusively used for educational purposes.

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.

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 violation of any provisions of applicable rules and regulations of the BIR, or the terms and conditions exemption. This certification shall be valid from the date of issuance until revoked by this Office for

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 documents as

Issued this day of_OCT 0 7 2022

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K-1 Commissioner of Internal Revenue LILIA CATRIS GUILLERMO 001893

HOME ORIENTED PRIME EDUCATION CHRISTIAN ACADEMY INC. CTE K Page 2 of 3 Date issued S3DH- 00 7 2022 408-2022

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION under Section 30(H) of the Tax Code Code of :997, as amended For Non-Stock, Non-Profit Educational Institution

TAX EXEMPTION 1) INCOME TAX. the payment of income tax only on revenues and receipts enumerated on the Certificate of Tax forth under Revenue Memorandum Order (RMO) No 44-2016, to wit: HOME ORIENTED PRIME EDUCATION CHRISTIAN ACADEMY INC. iS eXempt from Exemption. It is understood that the school must continue to meet the following requisites as set

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

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: 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 under the expanded foreign currency deposit system imposedjunder Section 27(D)(1) of the Tax Code of 1997, as amended, subject to compliance with the condjtions that as a HOME ORIENTED PRIME EDUCATION CHRISTIAN ACADEMY, INC.'s ihterest income

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 on interest income under the expanded foreign currency deposit system imposed by Section 27(D)(1) of the Tax 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.. the end of its taxable year.? 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 fdllowing construction and/or improvement of school buildings and facilities, acquisition of

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES) from taxation provided they are owned and operated by it as ancillary services. non-profit educational institution are exempt from VAT. Moreover, revenues derived from assets of HQME ORIENTED PRIME EDUCATION CHRISTIAN ACADEMY, INC. are exempt Pursuant to Section 109(1)(H) of the Tax Code of 1997, as amended, HOME ORIENTED PRIME used in the operation of cafeterias/canteens, dormitories and bookstores located within the premises EDUCATION CHRISTIAN ACADEMY, INC.'s gross receipts from operations as a non-stock.

LIABILITY FOR INTERNAL REVENUE TAXES 1) INCOME TAX income tax on all its income/receipts/revenues not expressly exempted and stated in the imposed under Tax 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, unless said revenues are actually, directly and exclusively used for educational purposes. HOME ORIENTED PRIME EDUCATION CHRISTIAN ACADEMY, INC. is subject to Certificate of Tax Exemption. Moreover, it is subject to the corresponding internal revenue taxes

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

HOME ORIENTED PRIME Page 3 of 3 EDUCATION CHRISTIAN ACADEMY, INC. CT Date issued S30H- 4 0 8 - 2 0 2 2 OCI_0 7 2022

2) VALUE ADDED TAX/PERCENTAGE TAX If HOME ORIENTED PRIME EDUCATIONCHRISTIAN ACADEMY, 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. services and importation of goods shall nevertheless be subject to the 12% VAT pursuant to Sections 106 to i08 of the Tax Code of 1997, as amended.

3) WITHHOLDING TAX 2-98, as amended, or if it makes income payments to individuals or corporations subject to the HOME ORIENTED PRIME EDUCATION CHRISTIAN ACADEMY, INC. shall be constituted as withholding agent for the govemment 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 Tax Code of 1997, as amended, as implemented by Revenue Regulations (RR) No. withholding tax pursuant to Section 57 of the Tax Code of 1997, as amended, and as implemented by RR No. 2-98, as amended.

1) The honoraria/allowances given to members of the Board of Trustees must be reasonable and TAXPAYER DUTIES & RESPONSIBILITIES subject to liquidation.

2) Required to file on or before the 1 5th 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 Tax 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 also required under Section 6(C) in relation to Section 237 of the Tax Code of 1997, which the Association is registered. 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

5)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.

5 Revenue Memorandum Circular No. (RMC) No. 76-2003 3 Republic Act No. 10963 increased the VAT threshold from P1,919,500.00 to P3,000,000.00 effective January 1, 2018 4 DOF Opinion No. 005-2019