BIR Ruling [DA-492-06]

August 10, 2006 BIR RULING [DA-492-06] Section 101 (A) (3); S30-056-2001 Bread of Life Ministries, Inc. CROSSROAD 77 Mother Ignacia Avenue cor. Scout Reyes St., Quezon City Attention: Mr. Pedro F. Galvez Corporate Secretary Gentlemen : This refers to your letter dated June 8, 2006 requesting for exemption from the payment of donor's tax relative to the donation in favor of Bread of Life Ministries, Inc. It appears that the Bread of Life Ministries, Inc ., is a non-stock, non-profit corporation duly organized and existing under the laws of the Philippines; that the Deed of Donation was executed by Bergita Echem Galvez as donor, and Bread of Life Ministries, Inc., as donee; that the object of the donation is a parcel of land covered by Transfer Certificate of Title No. T-25086, of the Registry of Deeds for the City of Cagayan de Oro; and that the donation was for and in consideration of the love and affection and in grateful appreciation of the donor to the donee, particularly in the latter's ministry in the propagation of the Gospel of Jesus Christ. In reply, please be informed that inasmuch as the donee is a religious organization, 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 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 imposed under Section 188 of the same Tax Code. aDHScI This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be ascertained 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