Request for Exemption of the Donation of a Parcel of Land in Favor of The Roman Catholic Archbishop of Manila

January 10, 1994 BIR RULING NO. 011-94 94 (a) (3) 301-92 011-94 The Roman Catholic Archbishop of Manila 121 Arzobispo Street Intramuros, Manila Attention: Msgr . Domingo A . Cirilos, Jr . S i r : This refers to your letter dated May 10, 1993 requesting exemption under Section 94(a)(3) of the Tax Code, as amended, of the donation made by the spouses Domingo and Liceria B. Soriano of a parcel of land located in Diliman, Quezon City, covered by Transfer Certificate of Title No. 277408 of the Register of Deed of Quezon City in favor of The Roman Catholic Archbishop of Manila by virtue of a Deed of Donation executed on December 17, 1991. Documents submitted show that the Roman Catholic Archbishop of Manila, is a religious corporation sole for the principal purpose of administering its temporalities. In reply, please be informed that inasmuch as the donee is a religious institution, the aforementioned donation is exempt from the payment of donor's tax pursuant to Section 94(a)(3) of the Tax Code, as amended, subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. Moreover, the aforesaid Deed of Donation is not subject to documentary stamp tax prescribed under Section 196 of the Tax Code, as amended but only to the documentary stamp tax of P3.00 imposed under Section 188 of the same Code. cdtech Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue