BIR Ruling

November 2, 1967 Mr. Numeriano B. Tabios Revenue District Officer Revenue Region No. 2 Laoag City S i r : In reply to your letter dated July 17, 1967, you are informed that pursuant to Section 2 of C. A. 465, otherwise known as the Residence Tax Law, the pertinent portion of which is quoted as follows: LLpr "Sec. 2. Entities liable to residence tax . Every corporation, no matter how created or organized, whether domestic or resident foreign, engaged in or doing business in the Philippines shall pay an annual residence tax of five pesos and an annual additional tax which in no case shall exceed two thousand pesos, . . .." the Divine Word College, being a religious educational institution not engaged in or doing business in the Philippines is not subject to the residence tax. However, if said institution owns real property and derives income therefrom it is subject to the basic and additional residence taxes pursuant to the aforequoted section. (BIR Ruling No. 161, series of 1961) prll Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue