BIR Ruling [DA-191-01]

October 17, 2001 BIR RULING [DA-191-01] Philippine Public Safety College Fort Bonifacio, Makati City Attention: Atty. Arturo D. Lipata Director, ILO Gentlemen : This refers to your letter dated June 28, 1999 requesting exemption from the payment of donor's tax on the donation of a parcel of land by Mr. Ray R. Juloya to the Philippine Public Safety College, Fort Bonifacio, Makati City represented by its Acting President Austere A. Panadero. It appears that Chapter VI, Section 66 of R.A. No. 6975, provides for the creation of the Philippine Public Safety College (PPSC), which shall be the premier educational institution for the training, human resource development and continuing education of all personnel of the PNP, Fire, and Jail Bureaus; that Mr. Ray R. Juloya is the registered owner of a parcel of land consisting of 16,000 square meters covered by Transfer Certificate of Title No. T-50523 issued by the Registry of Deeds for the Province of La Union; that the said parcel of land is situated in the Municipality of Aringay, Province of La Union where the Regional Training School I is presently situated and will cater to education and training needs of PNP members of the said Region purposely to enhance their knowledge and skills in Police Administration and Operations. In reply, please be informed that inasmuch as the donee is an entity created by law (R.A. No. 6975), which is not conducted for profit the aforesaid donation is exempt from the payment of donor's tax pursuant to Section 101 (A)(2) of the Tax Code of 1997. EcAHDT 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. Very truly yours, Commissioner of Internal Revenue By: (SGD.) EDMUNDO P. GUEVARA Deputy Commissioner Legal and Inspection Group