BIR Ruling [DA-261-99]
BIR Ruling [DA-261-99] • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • May 3, 1999
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May 3, 1999 BIR RULING [DA-261-99] Rizal State College Tanay, Rizal Attention: Mr . Jonathan R . Peada Director, RSC-Rodriguez Campus Gentlemen : This refers to your letter dated July 6, 1998 requesting for a ruling as to whether or not the Deed of Donation executed by the Municipality of Rodriguez in favor of Rizal State College, Tanay, Rizal covering several parcels of land with Transfer Certificates of Title No. 87155, 87154, 87153, 87120, 87121 and 87122, all located at Amityville Subdivision, San Jose, Rodriguez, Rizal, with a total land area of 38,688 square meters, is exempt from the payment of donor's tax and documentary stamp tax. Documentary evidence submitted disclosed that Rizal State College-Rodriguez Campus is a state college duly created, constituted and existing under and by virtue of the laws of the Republic of the Philippines; that Rizal State College-Rodriguez Campus was able to acquire the school site by virtue of donation from the Municipality of Rodriguez; and that these parcels of land shall be used solely for educational purposes. In reply, please be informed that inasmuch as the donee is an educational institution, the aforementioned donation is exempt from the payment of the 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 the said gifts shall be used by the donee for administration purposes. The Register of Deeds shall, however, annotate this condition at the back of the Transfer Certificates of Title. Moreover, the aforesaid Deeds of Donation are subject to documentary stamp tax of P15.00 each, imposed under Section 188 of the same Code. (BIR Ruling No. DA-195-97 dated April 28, 1997 and 108-94 dated May 30, 1994) This ruling is being issued on the basis of the foregoing facts as presented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. prcd Very truly yours, (SGD.) BEETHOVEN L. RUALO Commissioner of Internal Revenue
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