Exemption of Non-Stock, Non-Profit Educational Institutions from All Taxes on Revenues and Assets

March 10, 1988 BIR RULING NO. 093-88 24 237-87 093-88 Gentlemen : This refers to your letter dated July 27, 1987 requesting a ruling that the following non-stock, non-profit educational institutions duly authorized and recognized to operate as such by the Department of Education, Culture and Sports, viz: SCHOOLS LOCATION 1. School of the Holy Spirit Capitol Hills, Quezon City 2. Holy Spirit School Tagbilaran City 3. Holy Spirit Academy Loay, Bohol 4. College of the Holy Spirit Tarlac, Tarlac 5. Immaculate Academy of Malolos Malolos, Bulacan 6. Holy Infant Academy Calapan, Oriental Mindoro 7. Holy Spirit School Ilang-Ilang, Quezon City 8. Holy Spirit Academy Bangued, Abra 9. Holy Cross School Langanilang, Abra 10. Holy Spirit Academy Laoag City 11. Immaculate Conception Academy Batac, Ilocos Norte 12. Our Lady of Lourdes High School Manabo, Abra 13. Holy Ghost School Tayum, Abra 14. Holy Spirit Academy Irosin, Sorsogon are exempt from all taxes on revenues and assets used actually, directly and exclusively for educational purposes. In reply thereto, I have the honor to inform you that par. 3, Sec. 4, Art. XIV of the 1987 Constitution provides, viz: "(3) All revenues 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 aforementioned schools being non-stock, non-profit educational institutions are exempt from taxes and duties on all their 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