BIR Ruling No. 356-2020

BUREAU OF INTERNAL REVENUE REPUBLICOF THE PHILIPPINES DEPARTMENT OF FINANCE

D1 Quezon City

Certificate of Tax Exemption No.

Gb30-0356-202

CERTIFICATE OF TAX EXEMPTION

issued to

ONEWORLD MONTESSORI HOUSE,INC.

145 Salvador Extn., Banawa. Cebu City, Philippines

TIN: SEC Company Reg. No.

This certifies that the above-named corporation is a non-stock, non-profit educational

institution and has proven by actual operation that its primary purpose falls under Section 30

(H) of the National Internal Revenue Code (NIRC) of 1997, as amended. It is exempt from

INCOME TAX only on the following revenues or receipts:

I 4 2 3 Tuition fees and other miscellaneous school fees; Scholarship grants; Income derived from the operation of cafeterias/canteens, Donations; and dormitories and bookstores located within its premises, owned and

operated by ONEWORLD MONTESSORI HOUSE,INC.to be

actually, directly and exclusively used for educational purposes.

- 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 from the date of issuance until revoked by this Office

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

character, purpose or method of operation of the corporation which are inconsistent with the

basis for its income tax exemption.

This Certificate of Tax Exemption is being issued on the basis of the facts and

documents as represented and submitted. However, if upon investigation, the BIR ascertains

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

Issued this day of JUN 2 5 2020

1aesomwe

CAESAR R.DULAY

K1-FR-19-1444 K1-RPT Commissioner of Internal Revenue 035484 Q

ONEWORLD MONTESSORI HOUSE, INC. Page 2 of 3 Date Issued CTE No._SH3Q-0.3.5_6 - 2 0 2 0 JUN 2 5 2020

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

For Non-Stock, Non-Profit Educational Institution Under Section 30 (H of the National Internal Revenue Code of 1997, as amended

TAX EXEMPTION

1 INCOME TAX

ONEWORLD MONTESSORI HOUSE,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 school must continue to meet the following requisites as set forth under Revenue Memorandum Order (RMO) No 44-2016, to wit:

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

ONEWORLD MONTESSORI HOUSE, 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 15%' 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 15% 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 actual 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 15th day of the fourth

month following the end of its taxable year (Sec. 4, Finance Department Order

No. 137-87)2.

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

109(1)(H) of the National Internal Revenue Code of 1997, as amended, ONEWORLD

MONTESSORI HOUSE, INC.'s gross receipts from operations as a non-stock, non-profit

educational institution are exempt from VAT. Moreover, revenues derived from assets use in the

operation of cafeterias/canteens, dormitories and bookstores located within the premises of

ONEWORLD MONTESSORI HOUSE, INC., are exempt from taxation provided they are

owned and operated by it as ancillary activities.

LIABILITY FOR INTERNAL REVENUE TAXES

1 INCOME TAX

ONEWORLD MONTESSORI HOUSE, INC. is subject to income tax on all its

income/receipts/revenues not expressly exempted and stated in the Certificate of Tax

2 Department Order No. 149-95 dated November 24, 1995 amending Department Order No. 137-87 Republic Act No. 10963 increased the tax rate from 7.5% to 15% effective January 1, 2018. Q

ONEWORLD MONTESSORI HOUSE, INC. Page 3 of 3 Date IssuedJUN Z 5 2UZ0 CTENo.SH7.0035.6-20 20

Exemption. Moreover, it is subject to the corresponding internal revenue taxes imposed under the National Internal Revenue Code of 1997, as amended on its income derived from any of its for taxation, unless said revenues are actually, directly and exclusively used for educational properties, real or personal, or any activity conducted for profit, which income should be returned purposes.

2) VALUE-ADDED TAX(VAT)/PERCENTAGE TAX

If ONEWORLD MONTESSORI HOUSE, 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 Three Million Pesos (P3,000,000.003) or to the 3% percentage tax, if gross receipts do not exceed P3,000,000.00.

or services and importation of goods shall nevertheless be subject to the 12% VAT pursuant to Notwithstanding that it is a non-stock, non-profit corporation, its purchase of goods or properties Sections 106 and 107 of the National Internal Revenue Code of 1997, as amended.

3)WITHHOLDING TAX

government if it acts as an employer and its employees receive compensation income subject to the of 1997, as amended, 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 National Internal Revenue Code of 1997, as amended, and as implemented by Revenue Regulations No. 2-98, as amended. ONEWORLD MONTESSORI HOUSE,INC.shall be constituted as withholding agent for the withholding tax under Section 79 (A), Chapter XIII, Title II of the National Internal Revenue Code

TAXPAYER DUTIES & RESPONSIBILITIES

1 ONEWORLD MONTESSORI HOUSE, INC. is required to file on or before the 15th day of the

disposition of income. Copy of this Certificate of Tax Exemption shall be attached to the 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 fourth month following the end of the accounting period a Profit and Loss Statement and Balance aforementioned Annual Information Return. Sheet with the Annual Information Return under oath, stating its gross income and expenses

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

No.[RMC] No.76-2003). related to the activities for which the corporation is registered. (Revenue Memorandum Circular

4)Finally, it is subject to the payment of registration fee of PhP500.00 as prescribed in Section 236(B)

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

Republic Act No.10963 increased the VAT thresh 500.00 to 3,000,000.00 effective January 1,2018.