Exemption Granted to Hermano (San) Miguel Febres Cordero Medical Education Foundation, Inc.

May 4, 1988 BIR RULING NO. 177-88 24 316-87 177-88 Gentlemen : This refers to your letter dated November 12, 1987 requesting exemption of the Hermano (San) Miguel Febres Cordero Medical Education Foundation, Inc. from the 10% tax on its income as a private educational institution prescribed under Section 24(b) of the Tax Code, as amended by Executive Order No. 37; the 20% tax on its interest and/or yield on deposit substitute instruments and interest on its savings and time deposits; and the compensating tax on its importation of books and other educational materials and equipment to be actually, directly and exclusively used for its educational purposes. cdti 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 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 institution took effect as of said date. Such being the case, the Hermano (San) Miguel Febres Cordero Medical Education Foundation, (De La Salle University-Emilio Aguinaldo College) Inc. being a non-stock, non-profit educational institution is exempt from taxes e.g., 10% tax on its income as an educational institution; 20% withholding tax on its interest income and/or yield on deposit substitute instruments and interest on its savings and time deposits; customs duties and value-added tax on its importation of books and other educational materials and equipment to be actually, directly and exclusively used for educational purposes. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner