Request for Exemption from Payment of Donor's Tax on Donation of Parcel of Land to the Roman Catholic Archbishop of Manila

June 19, 1986 BIR RULING NO. 081-86 104 150-83 081-86 Gentlemen : This refers to your letter dated May 12, 1986 requesting exemption from the payment of donor's tax on the donation of a parcel of land located in Pinagbuhatan, Pasig, Metro Manila covered by O.C.T. No. 541(1813), made by Mr. Sixto Antonio in favor of your client, the Roman Catholic Archbishop of Manila by virtue of a Deed of Donation executed on February 25, 1985. It appears that the Roman Catholic Archbishop of Manila is a religious corporation sole duly organized and existing under the laws of the Philippines. In reply, please be informed that inasmuch as the donee is a religious corporation, the aforementioned donation is exempt from the payment of donor's tax pursuant to Section 104 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. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner