Exemption of the Student Cooperative Store of the Chiang Kai Shek High School

November 23, 1960 BIR RULING NO. 516-60 The Associate Director Principal Chiang Kai Shek High School 1274 Padre Algue & 1280 Alvarado Streets Manila, Philippines S i r : Reference is made to your letter dated February 23, 1959 requesting exception of the student cooperative store of the Chiang Kai Shek High School from the payment of internal revenue taxes. It appears upon investigation that the student cooperative store was organized by the student body upon permission of the school authorities. It caters exclusively to members of the faculty and the student body. The capital of the cooperative store is formed by requiring the students to contribute one peso (P1.00) upon enrollment which is refundable at the termination of the school year. If profits should be realized by the cooperative store such gains shall not be distributed to the officers nor to any body in the school management but the school shall use the money for fellowship of bright and poor students, for the advancement of athletics, literary and musical activities of the school. It was also noted that the said student cooperative store is staffed by regular students who are elected by the student body and they shall serve for the duration of the school year without compensation. As the personnel of the cooperative store are such regular students, they could afford to open only before the start and after dismissal of their regular classes and during recess. Under the circumstances, this Office is of the view and so holds that the cooperative store cannot be considered a business venture and, therefore, exempt from tax. aisadc Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue