BIR Ruling No. 380-2018

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE Quezon City

Certificate of Tax Exemption No. 380-2018

CERTIFCATE OF TAX EXEMPTION issued to

Plaza Amado V. Hernandez, Ilaya St., Brgy. 04, Zone 01, District I, Tondo, Manila 1012 HOLY CHILD CATHOLIC SCHOOL, INC. SEC Company Reg. No. TIN:

INCOME TAX only on the foliowing revenues or receipts: Section 30(H) of the National Internal Revenue Code of 1997, as amen&ed. It is exempt from and has proven by actual operation that its primary purpose is one of those enumerated under This certifies that the above-named corporation is a non-stock, non-profit corporation

2. Income derived from the operation of cafeterias/canteens, dormitories and 1. Tuition fees and Other school fees; CATHOLIC SCHOOL, INC., to be actually, directly and exclusively used for bookstores located within its premises, owned and operated by HOLY CHILD educational purposes.

nothing follow

character, purpose or method of operation of the corporation which are inconsistent with the basis for its income tax exemption. integral part hereof. It is liable, however, to all other taxes not enumerated above. for violation of any provisions of applicable rules and regulations of the BIR, or the terms and conditions herein set forth. It shall likewise be revoked if there are material changes in the 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 This certification shall be valid from the date of issuance until revoked by this Office

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

Issued this day of MAR 0 8 2018

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K-1-JAC Commissioner of Internal Revenue CAESAR R. DULAY W: .014 170

Holy Child Catholic School, Inc. Page 2 of 3 Date issued 3-8-2018 CTE NO. 380-2018

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION For Non-Stock, Non-Profit Educational Institutior under Section 30(H) of the National Internal Revenue Code of 1997, as Amended

TAX EXEMPTION

1) INCOME TAX. HOLY CHILD CATHOLIC SCHOOL, INC, is exempt from the payment of

income tax only on revenues and receipts enumerated on the Certificate of Tax Exemption. It is understood that the schoo! must continue to meet the following requisites as set forth under Revenue Memorandum Order (RMO).No 44-2016, to wit:

i.It is a non-stock, non-profit educational institution; and ii.. Its revenues are actually, directly and exclusively used for educational purposes.

HOLY CHILD CATHOLIC SCHOOL, INC.'s interest income from currency bank deposits and yield from deposit substitute instruments used actually, directly and exclusively in pursuance of its purpose as an educational institution, are exempt from the 20% final tax and 7 1/2% tax on interest income under the expanded foreign currency deposit system imposed under Section 27 (D) (1) of the National Internal Revenue Code of 1997, as amended, subject to compliance with the conditions that as a tax-exempt educational institution it shall on an annual basis submit to the Revenue District Office concerned an annual information return and duly audited financial statement together with the following:

(a)Certification from their depository banks as to the amount of interest income earned from passive investment not subject to the 20% final withholding tax and 7 1/2% tax on interest income under the expanded foreign currency deposit system imposed by Section 27 (D) (1) of the National Internal Revenue Code of 1997, as amended;

(b)Certification of actuai utilization of the said income; and

(c)Board Resolution by the school administration on proposed projects (i.e.) construction and/or improvement of school buildings and facilities, acquisition of equipment, books and the like) to be funded out of the money deposited in banks or placed in money markets, on or before the 1 5th day of the fourth month following the end of its taxable year (Sec. 4, Finance Department Order No. 137-87)

2) VALUE ADDED TAX (VAT) ON EDUCATIONAL SERVICES. Pursuant to Section

109(1)(H) of the NIRC, HOLY CHILD CATHOLIC SCHOOL INC.'s gross receipts from operations as a non-stock, non-profit educational institution are exempt from VAT.

LIABILITY FOR INTERNAL REVENUE TAXES

1) INCOME TAX

HOLY CHILD CATHOLIC SCHOOL, INC. is subject to income tax on all its income/receipts/revenues not expressly exempted and stated in the Certificate of Tax

Department Order No. 149-95 dated November 24, 1995 amending Department Order No. 137-87]

Page 3 of 3 Holy Chiid'Catholic Schoot, Ine. Date issued 3-8-2018 CTE No.380-2018

NIRC, as amended, on its income derived from any of its properties, real or personal, or any activity conducted for profit, which income should be returned for taxation, unless said revenues are actually, directly and exclusively used for educational purposes. Exemption. Moreover, it is subject to the corresponding internal revenue taxes imposed under

2) VALUE ADDED TAX/PERCENTAGE TAX

If HOLY CHILD CATHOLIC SCHOOL, INC. is engaged in the sale of goods or services in the course of a business pursuit, including transactions incidental thereto, its revenues derived therefrom shall be subject to the 12% VAT, in case the gross receipts from such sales exceed One Million Nine Hundred Nineteen Thousand Five Hundred Pesos (P1,919,500.00), or to the 3% percentage tax, if gross receipts do not exceed P1,919,500.00.

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

HQLY CHILD CATHOLIC SCHOOL, INC. shall be constituted as withholding agent for the government if it acts as an employer and its employees receive compensation income subject to the withholding tax under Section 79 (A), Chapter XII, Title II of the NIRC, as implemented 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, and as implemented by Revenue Reguiations No. 2-98, as amended.

TAXPAYER DUTIES & RESPONSIBILITIES

1) HOLY CHILD CATHOLIC SCHOOL, INC. is required to file on or before the 15th day of the

fourth month foliowing the end of the accounting period a Profit and Loss Statement and Balance 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 activities as well as sources and

disposition of income. Copy of this Certificate of Tax Exemption shall be attached to the aforementioned Annuai Information Return.

2) Under Section 235 of the National Internal Revenue Code of 1997, as amended, 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 National Internal

Revenue Code of 1997, as amended, 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 National Internal Revenue Code of 1997, as amended.