BIR Ruling

February 22, 1974 Rev. Byron W. Clark United Missionary Office 1750 Adriatico, Malate Manila S i r : This refers to your letter dated February 14, 1974 requesting exemption from the donor's gift tax the donation of three (3) parcels of land covered by Transfer Certificates of Title Nos. 111604, 51230 and 38691 all located in the District of Ermita, City or Manila. aisa dc It is represented that the Deed of Donation covering said real properties was executed on June 7, 1973 by the World Division of the Board of Global Ministries of the United Methodist Church, a non-stock, non-profit religious corporation organized and existing under the laws of the State of New York, U.S.A. and authorized to do business in the Philippines, as the DONOR, in favor of the Philippines Central Conference of the Methodist Church, a non-stock, non-profit religious corporation organized and existing under the laws of the Philippines with principal address at 900 U. N. Avenue, Ermita, Manila, as the DONEE. In reply, I have the honor to inform you that, pursuant to Section 112 of the Tax Code, as amended by Presidential Decree No. 69, gifts or donations made in favor of a religious corporation are exempt from the donor's gift tax. Such being the case, since the abovementioned donation was made in favor of the Philippine Central Conference of the Methodist Church, a religious corporation, the same is exempt from the donor's gift tax. However, it is a condition for the enjoyment of tax exemption that not more than 30% of the gift shall be used by the donee for administration purposes. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR.