bir_ruling BIR Ruling No. 452-2017BIR Ruling No. 452-2017

BIR Ruling No. 452-2017

REPUBLIC OF THE PHHLIPPINES DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No. 452-2017

CERTIFICATE OF TAX EXEMPTION

issued to

20/F Security Bank Centre, 6776 Ayala Avenuc, Makati City 1226 MENZI TRUST FUND, INC SEC Company Reg. No. TIN:

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

I. Donations.

nothing follow.

subject to the provisions of applicable BIR rules and regulations and the tax exemptions. liabilities and responsibilities stated in the Tcrms and Conditions hereto attached and made an integral part hercof. It is liable, however, to ali other taxes not enumerated above.

This certification shall be valid for three (3) years from the datc of issuance unless

of BIR. or the terrns and conditions herein set forth. carlier revoked by this Office for violation of any provisions of applicable rules and regulations

This Certificatc may be renewed upon filing of a subsequent application for revalidation

Certificate shall be deemed a revocation thereof upon the expiration of the thrce (3)-year provided under Revenue Memorandum Order (RMO) No. 20-2013. Failure to renew this

period.

documents as represented and submitted. However, if upon investigation. the BIR asceriains This Certificate of Tax Exemption is being issued on the basis of the Tacts and

that the facts are different. then this Certificate shall be considered null and void.

Issued this day of

Commissioner of Internal Revenue CAESAR R. DULAY

K-I-JAC

Cua c.U

Deputy Commissioner CELIA C'KING

Menzi Trust Fund, Inc. CTE NO. 42-C7 Page 2 of 3 Date issued 9--7

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

TAX EXEMPTION

1) INCOME TAX. MENZI TRUST_FUND,INC. is only cxempt from the paymcnt of income tax on revenues and reccipts enumerated on the Certificate of Tax Exemption. association/corporation/ organization must continue to meet the requirements set forth under Revenue Memorandum Order No. 20-2013. Morcover. lo be entitledto the tax exemptions enumeraied herein. the

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

regardless of the disposition thereof. which incomc should be returned for taxation. not expressly exempted and stated in the Certificate of Tax Exemption. Moreover, it is derived from any of its properties. real or personal. or any activity conducted for profit MENZI TRUST FUND, INC. is subject to income tax on all its income/receipts/revcnues subject to the corresponding internal revenue taxes imposed under the NIRC on its income

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

2) VALUE ADDED TAX

for VA'l on the revenues derived therefrom. if MENZI TRUST FUND INC. is engaged in the sale of goods or services in the course of a busincss pursuit. including transactions incidental thereto, in general. it shall be liable

VA'T' pursuant to Sections 106 and 107 of the NIRC. Notwithstanding that it is a non-stock. non-profit corporation. its purchase of goods or properties or services and importation of goods sha!l nevertheless be subject to the 12%

3) WITHHOLDING TAX

57 of' the NIRC. as implemented by Revenue Regulations No. 2-98. as amended. MENZI TRUST FUND, INC. shall be constituted as withholding agent for the subject to tie withholding tax under Section 79 (A), Chapter XI!1, Title HI of thc NIRC. as implementcd 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 government if it acis as an employer and its employees receive compensation income

Pagc 3 ot 3 Menzi Trust Fumd. Ine. Date issued 3-6-2017 CTE NO. :52-2017

TAXPAYER'S DUTIES & RESPONSIBILITIES

1) MENZI TRUST FUND, INC. is required to file on or before thc 15th day of the fourth

month following the end of the accounting period a Profit and i oss Statement and Balanee

change in its By-laws, Articles of Incorporation. manner of opcration and activities as well Shect 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

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 NIRC, any provision of existing general and special !aw 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

issuc duly registered receipts or sales or commercial invoices for each sale or transfer of merchandise or for services rendered which are not dircetly related to the activities for which the Association is registered. (Revenue Memorandum Circular No. [RMC| No. 76- 203

4) Finally. it is subject to the payment of registration fee of Php 500.00 as prescribed in Section 236(B) of the NIRC

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