Maranatha Christian Fellowship, Inc.

December 7, 2007 BIR RULING [DA-630-07] Section 30 (H) DA-329-2005 Maranatha Christian Fellowship, Inc. Maranatha Bldg., cor. P. Burgos & V. Guillas Sts., Cebu City Attention: Mr. Serico Orat Gentlemen : This refers to your letter dated June 26, 2007 which was indorsed to this Office by way of 1st Indorsement by Revenue Region No. 13, Cebu City requesting for exemption from the payment of donor's tax relative to the donation in favor of the Maranatha Christian Fellowship, Inc. DECcAS Documentary evidence submitted disclosed that the Maranatha Christian Fellowship, Inc. (Donee) is a non-stock, non-profit religious organization registered with the Securities and Exchange Commission under SEC Reg. No. 135130 dated September 15, 1986; that the primary purposes for which the corporation is organized are stated in the attached Articles of Incorporation; that the subject parcel of land is covered by Tax Declaration No. 17185, registered under the name of Bernardo C. Parcon married to Caroline-Lim Parcon (Donor) with an area of 13,753 square meters, more or less, located at Barangay Lupa, Compostela, Cebu; and that a Deed of Donation was executed by the donor and the donee dated June 21, 2007. 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. DcHaET 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