Tax Exemption of the Donations by a Non-stock Non-profit Religious Institution to a Religious Institution

October 27, 1992 BIR RULING NO. 301-92 94 (a) (3) 064-92 301-92 Atty. Fregillana, Jr., D.D. 2nd Flr., Manila Seedling Bank Bldg. Quezon Ave. cor. EDSA, Quezon City, Metro Manila S i r : This refers to your letter dated June 30, 1992 requesting exemption under Section 94(a)(3) of the Tax Code as amended, of the donations of two (2) parcels of land situated in the Barangay of Iruhin, Tagaytay City covered by Transfer Certificate of Title Nos. T-22418 and T-22419 respectively, both of the Register of Deeds for Tagaytay City, made by the ST. SCHOLASTICA'S COLLEGE in favor of the COMMUNITY OF BENEDICTINE SISTERS, by virtue of a Deed of Donation executed on May 30, 1992. Investigation conducted by this Office disclosed that the Community of Benedictine Sisters is a non-stock, non-profit religious institution duly registered as donee institution under Batas Pambansa Blg. 45, amending Section 29 (h) of the Tax Code, as implemented by BIR-NEDA Regulations Nos. 1-81 and 10-82. In reply, please be informed that inasmuch as the donee is a religious institution, the aforementioned donation is exempt from the payment of donor's tax pursuant to Section 94 (a)(3) of the Tax Code, as amended, subject to the condition that not more than 30% of said gifts shall be used by the donee for administration purposes. LLjur Very truly yours, JOSE U. ONG Commissioner of Internal Revenue