Tax Exemption Privilege of Non-stock, Non-profit Educational Institutions

August 11, 1987 BIR RULING NO. 237-87 24 000-00 237-87 Gentlemen : This refers to your letter dated May 22, 1987 requesting exemption of the International School from the 10% tax on its income as a private educational institution prescribed under Section 24(a) 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, the customs duties 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. 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 International School 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. aisadc Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner