United Methodist Church

February 23, 2007 BIR RULING [DA-120-07] Section 101 (A) (3) S30-056-2001 United Methodist Church Aritao, Nueva Vizcaya Attention: Mr. Catalino F. Melegrito Resident Pastor Gentlemen : This refers to your letter dated August 1, 2006 requesting for exemption from the payment of donor's tax relative to the donation in favor of the United Methodist Church of Aritao, Nueva Vizcaya. It appears that the United Methodist Church of Aritao, Nueva Vizcaya , is a non-stock, non-profit religious organization duly organized and existing under the laws of the Philippines; that the Deed of Donation was executed by Mercedita Bagasao Bautista and Ma. Elena G. Bagasao, as donors, and United Methodist Church, as donee; that the object of the donation is a parcel of land covered by Transfer Certificate of Title No. T-97796, of the Registry of Deeds for the Nueva Vizcaya; and that the donation was for the generosity and benevolence of the donor to the donee. In reply, please be informed that inasmuch as the donee is a religious organization, the aforementioned 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. ATDHSC Moreover, the Deed of Donation is not subject to the documentary stamp tax prescribed under Section 196 of the Tax Code of 1997, but only to the documentary stamp tax of P15.00 imposed under Section 188 of the same Tax Code. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be ascertained that the facts are different, then this ruling shall be considered null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service