The Roman Catholic Bishop of Novaliches

April 24, 2009 BIR RULING [DA-(DT-020) 210-09] 101 (A) (2); DA-217-08 dtd. 04/02/2008 The Roman Catholic Bishop of Novaliches Chancery Office, Cathedral of the Good Shepherd Regalado Avenue Ext., Fairview Park 1 Quezon City Attention: Most Rev. Antonio R. Tobias, DD Bishop Gentlemen : This refers to your letter dated March 30, 2009, requesting for exemption from the payment of donor's tax under Section 101 of the Tax Code of 1997. It appears that the Roman Catholic Bishop of Novaliches is the registered owner of a parcel of land consisting of 1,000 sq.m. situated in La Foretza Subdivision, Caloocan City covered by Transfer Certificate of Title (TCT) No. C-376385; that it donated the aforementioned property to the City Government of Caloocan City to be developed into and to be used as playground and other public purposes; and that the said City Government gratefully accepts the said donation. In reply, please be informed that inasmuch as the donee is a political subdivision of the National Government and the real property subject of said donation shall be exclusively utilized as a municipal playground and other public purposes, the aforesaid donation is exempt from the payment of donor's tax pursuant to Section 101 (A) (2) of the Tax Code of 1997, as amended. Moreover, the Deed of Donation executed for the purpose is not subject to the documentary stamp tax. However, the notarial acknowledgment on said deed is subject to the documentary stamp tax of P15.00 imposed under Section 188 of the Tax Code of 1997, as amended. 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. aTSEcA Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service