BIR Ruling [DA-199-00]

March 31, 2000 BIR RULING [DA-199-00] 196; 198 452-93 DA-199-2000 Blessed Sacrament, Inc. 20 Sunnyside Drive, New Manila Quezon City Attention: Bro . Salvador J . Yanzon, SSS Provincial Treasurer Gentlemen : This refers to your letter dated March 31, 2000 requesting for exemption from donor's tax and other taxes on the donation by the Blessed Sacrament, Inc. of its properties in favor of the Servants of the Blessed Sacrament,. Inc., with principal office address at Barrio Kaligayahan, Zabarte Subdivision, Novaliches, Quezon City, for the fulfillment of the religious ends of the latter. It appears that the Blessed Sacrament, Inc. executed a deed of donation conveying its properties covered by TCT Nos. T-72797, T-73169, T-72240, T-72239, T-105534 and T-105535 of the Registry of Deeds for Davao City in favor of the donee. In reply, please be informed that inasmuch as the donee is a religious institution, 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. Moreover, the aforesaid 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 under Section 188 of the same Code. This ruling is issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different from that as represented, then this ruling shall be considered null and void. llcd Very truly yours, Commissioner of Internal Revenue By: (SGD.) SIXTO S. ESQUIVIAS IV Deputy Commissioner (Legal and Enforcement Group)