BIR Ruling No. 399-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

X Quezon City

Certificate of Tax Exemption No. SA30-0399-2020

CERTIFICATE OF TAX EXEMPTION

issued to

SAINT MARY'S SCHOOL OF DUPAX,INC. Dopaj, Dupax Del Sur. Nueva Vizcaya 3707 SEC Company Reg. No. TIN:

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

1 Tuition Fees and Other School Related Fees;

3 Grants and Donations; and Income derived from the operation of cafeterias/canteens, dormitories,

Saint Mary's School of Dupax, Inc. to be actually, directly and and bookstores located within its premises, owned, and operated by exclusively used for educational purposes.

nothing follows

integral part hereof. It is liable, however, to all other taxes not enumerated above. 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

for violation of any provisions of applicable rules and regulations of the BIR, or the terms and character, purpose or method of operation of the corporation which are inconsistent with the conditions herein set forth. It shall likewise be revoked if there are material changes in the basis for its income tax exemption. This certification shall be valid from the date of issuance until revoked by this Office

that the facts are different, then this Certificate shall be considered null and void. documents as represented and submitted. However, if upon investigation, the BIR ascertains This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this day ofJUL 2 0 2020

Waeawa

-K-1-LMAT Commissioner of Internal Revenue CAESAR R.DULAY 035797

Q

SAINT MARY'S SCHOOL OF DUPAX, INC. CTENo.SH30-03g9-2020 Date issued 3JU 2 U 2020

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

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

SAINT MARY'S SCHOOL OF DUPAX, 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:

b) Its revenues are actually, directly and exclusively used for educational a)It is a non-stock, non-profit educational institution; and

purposes.

SAINT MARY'S SCHOOL OF DUPAX, INC.'s interest income 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 on (1) of the National Internal Revenue Code of 1997, as amended, subject to compliance with the interest income under the expanded foreign currency deposii system imposed under Section 27 (D) conditions that as a tax-exempt educational institution it shall on an annual basis submit to the statement together with the following: Revenue District Office concerned an annual information return and duly audited financial

a) Certification from their depository banks as to the amount of interest income

and 15% tax 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; earned from passive investment not subject to the 20% final withholding tax

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

c) Board Resolution by the school administration on proposed projects (i.e.. 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 or placed in money markets, on or before the 15th day of the fourth month following the end of its taxable year (Sec. 4, Finance Department Order No. 137-87)2.

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES

MARY'S SCHOOL OF DUPAX, INC.'s gross receipts from operations as a non-stock, non-profit Pursuant to Section 109(H) of the National Internal Revenue Code of 1997, as amended, SAINT MARYS SCHOOL OF DUPAX, INC., are exempt from taxation provided they are owned and operated by it as ancillary activities. educational institution are exempt from VAT. Moreover, revenues derived from assets used in the operation of cafeterias/canteens, dormitories, and bookstores located within the premises of SAINT

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

Department Order No. 149-95 dated November 24, 1995 amending Department Order No. 137-87 Republic Act (RA) No. 10963 increased the tax rate from 7.5% to 15% effective January 01. 2018 O

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SAINT MARY'S SCHOOL OF DUPAX, INC. CTENO.H30-0399-2020 Date issued _JUL2 0 2020

SAINT MARYS SCHOOL OF DUPAX, INC. is subject to income tax on all its income/receipts/revenues not expressly exem'pted and stated in the Certificate of Tax National Internal Revenue Code of 1997, as amended, on its income derived from any of its for taxation, unless said revenues are actually, directly and exclusively used for educational Exemption. Moreover, it is subject to the corresponding internal revenue taxes imposed under the properties, real or personal, or any activity conducted for profit, which income should be returned purposes.

2) VALUE ADDED TAX (VAT)/PERCENTAGE TAX

the course of a business pursuit, including transactions incidental thereto, its revenues derived If SAINT MARY'S SCHOOL OF DUPAX, INC. is engaged in the sale of goods or services in

therefrom shall be subject to the twelve percent (12%) VAT, in case the gross receipts from such sales exceed Three Million Pesos (P3,000,000.00)3, or to the three percent (3%) percentage tax, if gross receipts do not exceed Three Million Pesos (P3,000,000.00).

Sections 106 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 properties or services and importation of goods shall nevertheless be subject to the 12% VAT pursuant to

3)WITHHOLDING TAX

SAINT MARYS SCHOOL OF DUPAX, 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 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)SAINT MARY'S SCHOOL OF DUPAX, 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 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.

2) 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.

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

Revenue Code of 1997, 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 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 Php500.00 as prescribed in Section 236(B)

of the National Internal Revenue Code of 1997, as amended.

3 Republic Act (RA) No. 10963 increased the VAT threshold from P1,919,500.00 to P3,000,000.00 effective January 01.

2018

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