Kyungi Central Presbyterian Phil. Mission, Inc.

June 4, 2009 BIR RULING [DA-(DT-033) 274-09] 101 (A) (3); DA-618-2004 Kyungi Central Presbyterian Phil. Mission, Inc. Lot 5 Block 5 Rhea St., Crestview Subd. Cupang, Antipolo City Attention: Mr. Young-Won Kang President, Chairman of the Board Gentlemen : This refers to your undated letter requesting for exemption from the payment donor's tax that may be imposed on the donation made by Kyungi Central Presbyterian Phil. Mission, Inc. (Kyungi for brevity) to Crestview Jesus Mission Church Inc. (Crestview for short) pursuant to Section 101 of the Tax Code of 1997, as amended. cAISTC Documents submitted show that Kyungi with Tax Identification No. (TIN) 217-564-764-000, is a non-stock and non-profit religious corporation duly registered with the Securities and Exchange Commission (SEC) under Company Registration No. A200205344 dated April 3, 2002. On the other hand, Crestview with TIN 007-290-154-000 is likewise a religious corporation organized and existing under Philippine laws and is registered with the SEC pursuant to Company Registration No. CN200906439. Kyungi is the registered and absolute owner of a certain parcel of land located at Lot 5 Block 5 Rhea St., Crestview Subd., Cupang, Antipolo City with an area of 275 sq.m. as evidenced by Transfer Certificate of Title (TCT) No. R-15295 located in Barangay Cupang, Antipolo City. Kyungi now intends to donate the subject property to Crestview thru a Deed of Donation executed on May 27, 2009 for and in consideration of the latter's objective of community service and evangelization of the Gospel of the Lord Jesus Christ. In reply, please be informed that inasmuch as the donee is a religious corporation, the above-stated donation is exempt from the payment of donor's tax pursuant to Section 101 (A) (3) of the Tax Code of 1997. Moreover, the subject donation will not be subject to the documentary stamp tax prescribed under Section 196 of the Tax Code of 1997, but the Deed of Donation shall be subject to the notarial acknowledgment of P15.00 imposed under Section 188 of the same Tax Code. 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 as null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service