Eagle Ridge Golf & Country Club

November 11, 2008 BIR RULING [DA-(C-131) 414-08] 30; DA-158-2003; DA-125-2003 Eagle Ridge Golf & Country Club Javalera, General Trias, Cavite Attention: Mr. Juan Vicente O. Resurreccion General Manager Gentlemen : This refers to your letter dated May 12, 2008 requesting for a ruling that the membership dues being collected by Eagle Ridge Golf & Country Club from its bonafide members are not subject to income tax and/or withholding tax. It is represented that since Eagle Ridge Golf & Country Club started business operations in the year 2002, it has been collecting membership dues and that the membership dues being collected from the members are not treated as an income of the company; that the membership dues being collected and paid by the members are being used primarily to cover expenses related for the maintenance and improvement of the Club's facilities and premises; and that these membership dues are not income derived from real or personal property or from any activity conducted for profit. In reply, please be informed that as an exempt organization under Section 30 (E) of the 1997 Tax Code, as amended, and considering that the membership dues being collected by Eagle Ridge Golf & Country Club are not income derived from its real or personal property, or from any activity conducted for profit, said membership dues are not subject to income tax and consequently to the withholding tax (BIR Ruling Nos. S-30-26-01 dated March 28, 2001; undated BIR Ruling No. 103-79 and DA-158-2003 dated May 14, 2003). 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. SCEDaT Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service