Jubanitex, Inc.

May 28, 2008 BIR RULING [DA-323-08] Section 30; BIR Ruling No. S-30-096-99 Jubanitex, Inc. 4th & 5th Floor, #51 Guirayan St. Brgy. Doa Imelda, Quezon City Attention: Ms. Ma. Delia delos Santos Accountant Gentlemen : This refers to your letter dated January 3, 2008 requesting for exemption from the payment of donor's tax on the donation of fabric by Jubanitex, Inc. in favor of Asilo de San Vicente de Paul. As represented, Asilo de San Vicente de Paul formerly, Asilo-Colegio de San Vicente de Paul is a non-stock, non-profit social welfare institution registered with the Securities and Exchange Commission (SEC) under SEC Registration No. 1811. The primary purposes for which it was organized are as follows: "(a) To establish and operate a welfare agency to make visible the charity of Christ to the poorest of the poor as practiced by St. Vincent de Paul and St. Louise de Marillac so as to facilitate the empowerment of needy persons, families and communities. (b) To establish linkages with government, non-government and church organizations for networking on social issues." On the other hand, Jubanitex, Inc. is a domestic corporation registered with the Securities and Exchange Commission (SEC) under SEC Registration No. 161495 dated March 21, 1989. It is engaged "in the business of manufacture, marketing on wholesale only, buying or otherwise acquiring, holding, importing and exporting, selling and otherwise disposing of and dealing in embroidered textile products, fashion accessories, toys, furniture, household and office decorative wares, any and all kinds of articles made of materials of whatever kind and nature such as, but not limited to cloth, plastic, rubber, ceramics, wood, etc. ..." EIAScH In reply, please be informed that gifts in favor of an educational an/or charitable, religious, cultural or social welfare corporation, institution, accredited nongovernment organization, trust or philanthropic organization or research institution or organization are exempt from the payment of donor's tax pursuant to Section 101 (A) (3) and (B) (2) 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. 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.) JAMES H. ROLDAN Assistant Commissioner Legal Service