BIR Ruling No. 517-2017

REPUBLIC OF THIE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Fxemption No.

:*

CERTIFICATE OF TAX EXEMPTION

issued to

P&A FOUNDATION, INC. 20th Floor. Tower 1, The Enterprise Center. 6766 Ayala Avenue, Makati City SEC Company Reg. No. TIN:

National Internal Revenue Code of 1997, as amended. It is exempt from INCOME TAX only and has proven by actual operation that its primary purpose falls under Section 30 (E) of the This certifies that the above-named corporation is a non-stock, non-profit corporation

on the following revenues or receipts:

1. Donations/contributions from donors.

nothing follow.

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 for three (3) years from the date of issuance unless earlier revoked by this Office for violation of any provisions of applicable rules and regulations of BIR, or the terms and conditions herein set forth.

This Certificate may be renewed upon filing of a subsequent application for revalidation provided under Revenue Memorandum Order (RMO) No. 20-2013. Failurc to renew this Certificate shall be deemed a revocation thereof upon the expiration of the three (3)-year period.

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

Issued this day of NOV 0 7 20i7

1araaiy

P&A Foundation, Inc. K-1VDPM14 Commissioner of Internal Revenue CAESAR R. DULAY 010972

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OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

TAX EXEMPTION

b) lNCOME TAX. P&A FOUNDATION,INC.is only exempt from the payment of Moreover, to be entitled to' the tax exemptions association/corporation/ organization must continue to meet the requirements set forth income tax on revenues and receipts enumerated on the Certificate of Tax Exemption. under Revenue Memorandum Order No. 20-2013 enumerated herein. the

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

P&AFOUNDATION,INC.issubjecttoincome tax O ay its income/receipts/revenues not expressly exempted and stated in the Certificate of Tax activity conducted for profit regardless of the disposition thereof, which income should be returned for taxation. Exemption. Moreover, it is subject to the corresponding internal revcnue taxes imposed under the NIRC on its income derived from any of its properties, real or personal, or any

seven and one-half percent (7-1/2%) final withholding income tax pursuant to Section Likewise, interest income from currency bank deposits and yield or any other monetary benefits from deposit substitute instruments and from trust funds and similar arrangements. and royalties derived from sources within the Philippines are subject to the twenty percent depository bank under the expanded foreign currency deposit system shall be subject to 27(D)(1) in relation to Sec. 57(A) both of the NIRC. (20%) final withholding tax: Provided, however, that interest income derived by it from a

2) VALUE ADDED TAX

course of a business pursuit, including transactions incidental thereto, in general, it shall be If P&A FOUNDATION, INC. is engaged in the sale of goods or services in the liabic for VAT on the revenues derived therefrom.

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 Sections 106 and 107 of the NIRC.

3) WITHHOLDING TAX

P&A FOUNDATION, INC. shall be constituted as withholding agent for the government if it acts as an empioyer and its employees receive compensation income subject to the withholding tax under Section 79 (A), Chapter XIII, Title II of the NIRC, as impiemented 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 NIRC. as implemented by Revenue Reguiations No. 2-98, as amended.

TAXPAYER'S DUTIES & RESPONSIBILITIES

1) P&A FOUNDATION, 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

N

P&A FOUNDATION. INC Page 3 of 3 Date issued_11-7-&07 CTE No. 517-2017

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 activitics as well

as sources and disposition of income. Copy of this Certificate of Tax Excmption shall be

attached to the aforementioned Annual Information Return.

2) Under Section 235 of the NIRC, 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 NIRC 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 PhP 500.00 as prescribed in Section 236(B) of the NIRC