BIR Ruling [DA-405-98]

September 7, 1998 BIR RULING [DA-405-98] Ms. Aida V. Via 36 Tandang Sora Avenue Diliman, Quezon City M a d a m : This refers to your letter dated July 13, 1998 requesting for a ruling on the tax consequence of your donation of two (2) parcels of land in favor of the Iglesia Ni Cristo. aisadc It appears that on July 14, 1998, you executed a Deed of Donation in favor of Iglesia Ni Cristo over two (2) parcels of land covered by TCT No. 112370 of the Registry of Deeds for the Province of Cavite and TCT No. N-153949 of the Registry of Deeds for Quezon City. In reply, please be informed that inasmuch as the donee is a religious organization, the abovementioned 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 gifts shall be used by the donee for administration purposes. The Deed of Donation shall be subject to the documentary stamp tax imposed under Section 188 of the Tax Code of 1997. (BIR Ruling No. 090-93 dated March 10, 1993) This ruling is issued on the basis of the foregoing representations. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. LLpr Very truly yours, (SGD.) SIXTO S. ESQUIVIAS IV Deputy Commissioner (Legal & Enforcement Group)