Philippine Pentecostal Holiness Church, Inc.

May 16, 2007 BIR RULING [DA-300-07] 101 (A) (3) 044-2002 Philippine Pentecostal Holiness Church, Inc. 1887 Orense St., Guadalupe Nuevo, Makati City Attention: Bishop Ariel C. Moneda National Chairman, PPHCI Gentlemen : This refers to your letter dated August 01, 2006 requesting exemption from the payment of donor's tax on the donation of four (4) parcels of land owned by Spouses Roel N. Nadal and Araceli A. Nadal to Philippine Pentecostal Holiness Church, Inc. It appears that Spouses Roel N. Nadal and Araceli A. Nadal is the registered owner of four (4) parcels of land located in Barangay Tabuco, Naga City, covered by Transfer Certificates of Title Nos. 51091, 51092, 51093 and 51094 issued by the Register of Deeds of Naga City; that Philippine Pentecostal Holiness Church, Inc. is a non-stock, non-profit religious corporation duly registered with the Securities and Exchange Commission under SEC Registration No. 63882; that its vision is to multiply and mature believers and churches in worship, fellowship, and evangelism as its walk in obedience to the Great Commission in cooperation with the whole body of Christ; and that for and in consideration of the love and affection, and being believers in the Lord Almighty and as among the obedient followers of the Lord Jesus Christ, Spouses Roel N. Nadal and Araceli A. Nadal conditionally transfer and convey by way of donation to Philippine Pentecostal Holiness Church, Inc. the above-mentioned real properties free from all liens and encumbrances. In reply, please be informed that inasmuch as the donee is a religious non-stock, non-profit 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, as amended, subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. The Register of Deeds shall, however, annotate this condition at the back of the Transfer Certificate of Title because failure to comply with the said condition shall be a ground for the revocation of the donation pursuant to Article 764 of the New Civil Code. AaCcST Moreover, the Deed of Donation that will be executed for the purpose 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-044-2002 dated March 12, 2002) 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, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service