BIR Ruling No. 372-2022

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Date: 2640 oT- Section 1l of Republic Act No. AUG 2"3 2I2Z 3 7 2 -2 022 Tel Nos. 898 1-7328 / 8981-7327 Person to Contact: Chief, Law & Legislative Division

VETERANS FEDERATION OF THE PHILIPPINES Brgy. 659-A Zone 071 Gatpuno Villegas St. Ermita, Manila

Attention: VET. MANUEL R. PAMARAN (JUSTICE Ret.)

Acting President

Gentlemen:

Certificate of Tax Exemption ("CTE") from any and all taxes pursuant to Section 11 of Republic Act ("RA") No. 2640'. This refers to your request on behalf of Veterans Federation of the Philippines ("VFP") for a

owned and controlled corporation. It was organized for the purposes under Section 4 of the said Act, to 1960 and classified as a government instrumentality with corporate powers which is not a government- Wit: Documents submitted disclosed that the VFP was created under RA No. 2640 dated June 18.

1 To uphold and defend the democratic way of life as envisioned in the Constitution

2 3 To coordinate the efforts of all different veterans of the Philippines in behalf of the To represent and defend the interests of all Filipino veterans; of the Republic of the Philippines:

4 To promote mutual help among former comrades-in-arms; interest of respective members;

5 6. To perpetuate their common experience in wars; To undertake acts of charity and relief works;

8. To foster love of country and things Filipino and inculcate individual civic To preserve peace and order; and

consciousness.

Moreover, VFP's Financial Statement shows that it derives its revenue from the following:

Interest income Penalty Lease Rental income Lot Rental income Stickers Road Users income Service fee DESCRIPTION AMOUNT P P: P P P P P

1 An Act to Create a Public Corporation to be known as the Veterans Federation of the Philippines. Defining Its Powers. and for Other Purposes

CYt 3 7 2 - 2 0 2 2

AUG 2 3 2022

Condo Rental income Miscellaneous income Registration/Membership/ID P P F income TOTAL P

Hence, this request.

exermpted from payment of any and all taxes. In reply, please be informed that Section 1 1 of RA No. 2640 provides that the VFP is expressly

public funds, and can be used only for public purposes. 155027, February 28, 2006, ruled that the funds in the hands of the VFP from whatever source are Moreover, the Supreme Court in Veterans Federation of the Philippines v. Reyes, G.R. No.

public funds, and can only be used for public purpose, it follows that the same should likewise be exempt from taxes. Thus, considering that the income in the hands of the VFP, regardless of its source, is considered

enjoyed by VFP was already repealed by Section 86(e) of RA No. 10963. However, insofar as the value added tax ("VAT") is concerned, the exemption previously

In view of the foregoing, this Office hereby rules that the income of VFP from whatever source 1 is exempt from payment of any and all taxes, except for VAT, provided that the same shall only be used for public purpose.

and void. investigation, it will be ascertained that the facts are different, then this ruling shall be considered null This ruling is being issued on the basis of the foregoing facts as presented. However, if upon

Very truly yours,

Commissioner of Internal Revenue LILIA CATRIS GUILLERMO Wal l bhuil

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