BIR Ruling No. 353-2017

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE T Quezon City

Certificate of Tax Exemption No.

353m2017

CERTIFICATE OF TAX EXEMPTION

issued to

THE ANDRES SORIANO FOUNDATION, INC.

A. Soriano Aviation Hangar, Andrews Avenue, Pasay City SEC Company Reg. No. TIN:

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

1.Donations/grants.contributions 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.

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. Failure to renew this Certificate shall be deemed a revocetion thereof upon the expiration of the three (3)-year period.

This Certificate of Tax Exemotion is bein issued on the basis of the facts and documents as represented and submitted. Hewever, if upon investigation, the BIR ascertains that the facts are different, then this Certificate shall oe considered null and void

Issued this day of : AUG 08 2017

a

CAESAR R.DULAY Commissioner of Internal Revenue S 008354

The Andres Soriano FoundationIn K-1VDPM14

Page 2 of 3 THE ANDRES SORIANO FOUNDATION, INC CTE NO Date issued 2017 00

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

TAX EXEMPTION

1 INCOME TAX.THE ANDRES SORIANO FOUNDATION,INC.is only exempt from

association/corporation/ organization must continue to meet the requirements set forth the payment of income tax or revenue and receipts enumerated on the Certificate of Tax Exemption. Moreover, to be entitled to the tax exemptions enumerated herein, the under Revenue Memorandum Order No.20-2013.

LIABILITYFORINTERNAL FEVFNUETAXES

1 INCOME TAX

income/receipts/revenues not expressly exen pted and stated in the Certificate of Tax THE ANDRES SORIANO FOUNDATION, INC. is subject to income tax on all its

Exemption. Moreover, it is subiect to the corresponding internal revenue taxes imposed

activity conducted for profit regardless of the disposition thereof, which income should be under the NIRC on its incore derived from any of its properties,real or personal,or any returned for taxation.

Likewise, interest income fron curencv 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

seven and one-half percent (/-1/2%/) final withholding income tax pursuant to Section 27D1)in relation to Sec.57(A both of the NIRC (20% final withholding tax: Provided. however. that interest income derived by it from a depository bank under the expanded foreign currency deposit system shall be subject to

2) VALUE ADDED TAX

If THE ANDRES SORIANO FOUNDATION, INC. is engaged in the sale of goods or services in the course of a bsiness pursuit. irctding transactions incidental thereto. in general, it shall be liable for VA'T on. the reventes 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

THE ANDRES SORIANO FOUNDATION.INC.shall be constituted as withholding agent for the goverrment if it acs as an em'ovar ard its employees receive compensation income subject to the withholding tax under Section 79(A).Chapter XIII.Title Il of the NIRC,as impemented by Revene Regulatic No.2-98.as amended.or if it makes

Section 57 of the NIRC, as implemented by Revenue Regulations No. 2-98, as amended. income payments to individuals or corporations subiect to the withholding tax pursuant to

TAXPAYER'SDUTIESSREEPONSIBILITIES

1) THE ANDRES SORIANO 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 Sheet wit re Anrual Infermation Return under oath. stating its

THE ANDRES SORIANO FOUNDATION, INC CTE No. 3532017 Page 3 of3 Date issued 8&201

gross income and expenses incurred during the preceding period and a certificate showing that there has not been any change in its By-isws. Articies of Incorporation. manner of operation and activities as well as sources and disposition of income. Copy of this Return. Certificate of Tax Exemption shall be attached to the aforementioned Annual Information

2) Under Section 235 of the NIRC, any provision of existing general and special law to the purposes of ascertaining compliance with the conditions under which it has been granted contrary notwithstanding.the bcols of accounts and other pertinent records of tax-exempt organization or grantees of tax incentives shall be subject to examination by the BIR for 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 commerciai invoices for each sale or transfer of merchandise or for services rendered which are not directly related to the activities fon 2003) which the Association is registered.(Revenue Memorandum Circular No.[RMC] No.76

4) Finally, it is subject to th: paymept of registration fee of PhP 500.00 as prescribed in Section 236(B) of the NIRC