BIR Ruling [DA-064-01]
BIR Ruling [DA-064-01] • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • Apr 18, 2001
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April 18, 2001 BIR RULING [DA-064-01] 101 (A) (3) 481-98 Bulacan Association of Jehovah's Witnesses, Inc . Kingdom Hall of Jehovah's Witnesses Masagana Homes Phase II Guiguinto, Bulacan Attention: Mr . Leonardo B . Santiago, Jr . Malanday Congregation Representative Gentlemen : This refers to your letter dated November 6, 2000 requesting exemption from the payment of donor's tax on the donation of a parcel of land by Spouses Romulo and Norma Ducusin to the Bulacan Association of Jehovah's Witnesses, Inc. It appears that Bulacan Association of Jehovah's Witnesses, Inc. is non-stock, non-profit religious corporation duly registered with the Securities and Exchange Commission on October 22, 1990 under SEC Registration No. 182865; that Spouses Romulo and Norma Ducusin is the registered owner of a parcel of land consisting of 213 square meters situated at Valenzuela, Metro Manila covered by Transfer Certificate Title No. T-105901 issued by the Registry of Deeds of Caloocan City; and that a portion of said land consisting of One Hundred (100) square meters was donated to the Bulacan Association of Jehovah's Witnesses, Inc. In reply, please be informed that inasmuch as the donee is a religious corporation, the aforesaid donation is exempt from the payment of donor's tax pursuant to Section 101(A)(3) of the Tax Code of 1997, subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. Moreover, the Deed of Donation is not subject to documentary stamp tax. However, the acknowledgment on said deed is subject to the documentary stamp tax of P15.00 imposed under Section 188 of the Tax Code of 1997. (BIR Ruling No. DA-481-98 dated November 9, 1998) This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. DCcSHE Very truly yours, (SGD.) MILAGROS V. REGALADO Acting Assistant Commissioner Legal Service
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