Exemption of the Naga College Foundation from the Payment of Income Tax

February 10, 1988 BIR RULING NO. 031-88 24 000-00 031-88 Gentlemen : This refers to your letter dated November 25, 1986 requesting exemption of the Naga College Foundation from the payment of income tax in view of its conversion to a non-stock and non-profit foundation under Republic Act No. 6055. In reply thereto, I have the honor to inform you that paragraph 3, Section 4, Article XIV of the 1987 Constitution provides, viz: "(3) All revenue and assets of non-stock, non-profit educational institutions used actually, directly and exclusively for educational purposes shall be exempt from taxes and duties. . . ." The aforementioned Constitution was ratified at a plebiscite held for the purpose on February 2, 1987. Accordingly, the tax exemption privilege of non-stock, non-profit educational institutions took effect as of said date. Such being the case, the Naga College Foundation being a non-stock, non-profit educational institution is exempt from taxes and duties on all its revenues and assets used actually, directly and exclusively for educational purposes as of February 2, 1987. cdt Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner