BIR Ruling

May 16, 1969 Prof. Avelina R. Luis Philippine Normal College Taft Avenue, Manila M a d a m : This refers to your request for the exemption of the Philippine Normal College Exchange from the fixed and percentage taxes. Investigation conducted on the actual business operations and activities of the Philippine Normal College Exchange disclosed the following: The exchange is a joint project of the College and its faculty, employees and students. It operates a canteen and store for school supplies. It charges prices almost at cost and the little profits derived are used for scholarships and to help in the upkeep of the College. No part of the profits inures to the benefit of any private individual. Upon liquidation members are only entitled to a return of their investments. Any excess in assets will be donated to the College. In the light of the foregoing facts, it is the opinion of this Office as it hereby holds that the PNC Exchange is not engaged in business as this term is understood in internal revenue taxation and, therefore, is not subject to any internal revenue tax on business. cdtech Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue