BIR Ruling No. 91-2018

RTPUBLIC OF'IHE PHILIPPINES DEPARTMENT OF FINANCE BUREAU OF INTERNAI. REVE]-IUE Quezon CifS' Certiflcate of Tax ExemPtion No' a9'L-Za1': CERTIFICATE OF TAX EXEMFTION issued ro ,u",*ffi t,,t TIN: SEC ComPan)/ Reg. No. a'ci This ceniiies that the abcve-namecl corporatiOti is a non-stock, non-profit corpolation has proverl b,v actual operation ihar its plimary frurpose falls uirder Section 30 (E) of tire National intemat itevenue bode of 1997.^ ai amended. lt is exernpt fi'om INCOME'fAX oniy on the fbllowing l'evenues or receipts: 1. l)onations -nothing lbllow's'--- sr-rbject ro tlre provisions cf applicable BIR iules ernd regulatioils and the tax exemptions' lialiilities and responsibilities siateci iri the Terms and Conclitions hereto attached and rnade an integral part heretf. lt is liable. however. to all other taxes not enumerated abo','e. 'I'his certiflcatiol shali be vaiid fbr three (3) years ft'om the date of issuance unless earlier revokeil by this office for violation of any provisions of applicabie rules and reguiations oi'BlR, <.rr the terms anti conditions i-rerein set forth' Tiris Certiiicate rnal,be renewed upon filing of a subsequen-r application fbr revaiidation provideC under Revenue Memorandum Or,ler (RfUOl No. 20-2013' Failure to renew this Certificate shall be cleemed a i'evocation thereof'r-rpon the expiration of .the three (3')-year pci'iod. This Certifrcate of Tax Exemption is being issued on the basis of the facts and ciocurlerts as represented ancl subrnitted. l{owever, itupon investigation. the BiR ascertains thai the facts are different. then this Cefiiticate shall be considered nrill and void. Issued this day'ol CAESAR R" DUI-AV Commissioner of Internal Revenue K- I..IAC !t.^ driJ,{/& ii LnAA"q Cg8"f,rr C. K!ruq Depelf./ Corn rnissioner Rcs;ou ;"cf l#a nagei"nent fi r*un

St. lUladeleine Sophie Foundution, Inc. CTENo. cq:r-ZO1t Pa.ge 2 oi 3 Date issued .. :/ ':n<t. TtrRMS AND CONDITIOI{S OF TFTE CERTIFICATE OF'TAX EXEMPTION TAX EXEMPTION t ) ItNh.CpOuM1'-E"nTt AofXin. ST. MApELEINE SOPF{IE FOUNDATION. {NC. is o!1',e}iempt from Certificate of Tax efated on the E;.;i;io". Moreover. to be enritled to tire tax exemptions enumerated herein. the ario"iutiorucorporatioru' organization must contintie to meet the requirements set forth under Revenue Memorandum Order No. 20-2013. LIABII,ITY FC}R INTEITF{AL REVENTIE TAXF],S 1) INCOME TAX sT. MADELEINE SOPE{XE FOUNDATION. lNq. is; .subject to incorne tax on all its in the Certificate of Tax and stated Exemption. \4or-oo".. it is subiect to iire comesponding internal revenue taxes imposed under the NIRC on its income derived ti'om any bf its pri,perties, real or personal. or ?ly activity conducted lbr profit regardless of the disposition thereoi rvhich income should be returned for taxation. Likewise. interest income fi-om ourrencl barik deposits and y'ield cr any other monetarv benefits from deposit substiiute instruments and fiom trust funds and simiiar arranqements. and rol,aities derlived from sources rvithin the Philippines are s.ubject to the twenty p-ercent (20rh)"final withholding tax: Provided. however, tfiat interesi income derived by it fi'orr a depository bank underlhe expanded foreign cry1elll deposit s1'stem shail be sub_iect to ,"u"r, and one-half percent (i-112%) final v"'ithhoiding income tax pursuaut to Sectioli 27(D\(1) in relaticn to Sec. 57(A) both of the NIRC. 2) VAI.UE ADDED TAX If'ST. MADELEIT\tr SOPHIE FOUNDA'rION is engagbci in the. saie of.goods or sercludingtransactionsitlciden1a]tlrereto.in general. it shall be liable for VAT on the revenues derived therefi'om. l',lotwitkrstanding that if is a non-stock. non-profit corporation, its purchase of goods-or propefiies or se*rriices and importation of goods shall nevertheless be subject ta the l2oti V.{T or-rsuant to Sections 1 06 and 107 of the NIRC. 3) WrTFlL|OLDING TdX ST. pIADELEINE SOPI{IE FOUNDATTON.INC. shall be constituted as witirholding agent @ismubpijlaeecmnt*eetonmtteircpel 1wboiythyRheoerlvdaeinnngudetiatRsxeeugnmudlaeptriloSoneyscetNioenos.7r29e-(9cA8e),.iavCsehaacpmoteemrnXd_eIIdpI,"eoTnritsiiefaltiltioomfnatihkterecNsoIiRnmcCoe.tnaes payrnents to individuais or corporations subject to the witiiholding tax pursuant to Section -SZ-of the NIRC. as irnplemented b.v- Revenue Regulations No. 2-98, as amended. &*$=

St. frIadeleine Sophie Fo undation, Inc. CTE No. crg{*r#j$ I Page 3 or'3 Date issLred t*-Bt*Pf!l TAXPAYER'S DTiTIES & RESPONSIBILITIES )1'/ ST. MADELEINE EOPIroE FOUNDATION. INC. is reqr,iired to file on 01'before the 15th e end of the accourlting period. a Profit and Loss Statement and.Balance Sheet with the Annual Information Return under oath, stating its gross income and expenses incurreC during tire preceding period and a certificate showing lhat there has not been any change in its-By-iaws, Articles of Incorporation, mann-er.of operation and acrivities as weli-as sources and disposition of income. C9RV of this Certificate of Tax Exernption shall be attached to the aforementioned Annual information Return. 2'l Under Section 235 of the NIRC, any provision of existing general and sqecial iaw to the contrarv notwithstanding. the bcoks of accounts and other periinent records_ of tax-ellmpt organization or grantees of tax incentives shall be subject to examination by the BIR for pulrposes of ascertaining compiiance with the'conditions under which it has been granted tax-exemptions or tax incentii,es. anci its tax liabilities, if any. 3) Further, it is also required under Section 6(C) in relation to Section 237 of the NIRC to issue drily registered receipts or sales or corrrrrercial invoices for each sale or transfer of merchandise or for sen'ices rendered which are not directly related to the activities for which the Association is registered. (Revenue Memorandum Circr"rlar Nc. [RMC] No. 76- 2003). , 4) Finaliy. it is subject to the pal,rnent of registration fee of PhP 500.00 as prescribed in Section 236(8) of the NIttC.