Internal Revenue Tax Exemption granted to DOH- Cooperative Association

February 11, 1958 BIR RULING NO. 082-58 The Department of Health Cooperative Association San Lazaro Hospital Compound Manila Attention : Mr . Enrique T . Ochoa Secretary Gentlemen : I have the honor to acknowledge receipt of your letter dated October 31, 1957 requesting exemption from payment of internal revenue taxes under the provision of Republic Act No. 2023. cdt Section 66 of said Act provides as follows: "SEC. 66. Exemptions . Co-operatives registered under this Act shall, notwithstanding the provisions of existing law to the contrary, enjoy the following exemptions: "(1) Co-operatives with net assets of not more than five hundred thousand pesos shall be exempt from all taxes and government fees of whatever name and nature except those provided for under this Act: Provided, however, That co-operatives having net assets in excess of five hundred thousand pesos shall pay taxes as provided hereunder: "(a) Income Tax they shall pay tax at the full rate as provided under existing laws on the amount allocated for interest on capital; "( Sales Tax they shall pay fixed and percentage taxes at the full rate as provided under existing laws on gross sales to non-members; and "(c) They shall pay all other taxes, unless otherwise provided herein at the full rate as provided under existing laws." xxx xxx xxx According to the certification of your treasurer, Mr. Ladislao L. Dimaliuat, a copy of which is attached to the articles of incorporation submitted to this Office, the total paid up capital of the association is only P2,692.00. The Cooperative Administration Office in its letter dated October 28, 1957 also certified that your association is a cooperative registered with the Securities and Exchange Commission under Registration Certificate No. 8375, dated December 12, 1953 and is under the supervision of said office. In view of the foregoing, your association is exempt from the payment of internal revenue taxes in accordance with the above-quoted provisions of Republic Act 2023. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue