Revenues Derived from Sale of Property by a School Used for Educational Purposes - Exempt from Tax but Subj. to Doc. Stamp Tax

December 29, 1993 BIR RULING NO. 552-93 REVENUES DERIVED FROM SALE OF PROPERTY BY A SCHOOL USED FOR EDUCATIONAL PURPOSES EXEMPT FROM TAX BUT SUBJ. TO DOC. STAMP TAX 24 (b) Sec. 4 (3) 388-93 552-93 Carlos J. Valdez & Co. CJVC Bldg., Aguirre Street Legaspi Village, Makati Metro Manila Attention: Mr . Romeo C . Alba Managing Partner This refers to BIR Ruling No. 24(a)-115-92-388-93 dated September 16, 1993 stating, among others, that the revenues derived from the sales of real property by St. Scholastica's College which are used actually, directly and exclusively for the construction of a new school building in furtherance of its educational purposes is also exempt from documentary stamp tax. Please be informed that after a re-study of the case, the said ruling is hereby modified subjecting said transaction to documentary stamp tax. The tax exemption clause under paragraph 3, Sec. 4, Article XIV of the 1987 Constitution covers only exemption from tax imposition on all revenues and assets. It does not cover the tax burden from documentary stamp tax which is a tax on a document executed between or among the parties by virtue of a transaction. aisadc LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue