Philippine Canine Club, Inc.

November 20, 2009 BIR RULING [NSNP-(S30C-028) 726-09] Section 30 (C) Philippine Canine Club, Inc. Rm. A206 Hillcrest Condominium, E. Rodriguez Blvd. Cubao, Quezon City Attention: Mr. Ronnie F. Natividad President/CEO Gentlemen : This refers to your letter dated September 20, 2009 requesting for a renewal of your certificate of tax exemption. cAEDTa Documents show that the Philippine Canine Club, Inc., with Taxpayer Identification No. 917-096-000, is a non-stock, non-profit corporation registered with the Securities and Exchange Commission under Certificate of Registration No. 22739. Its purposes are "(t)o maintain and protect the integrity of its Registry of purebred dogs, to publish an official Registry of purebred dogs (the 'stud book'), to adopt and enforce uniform rules regulating and governing purebred dog registration and purebred dog events, to regulate the conduct of persons and organizations interested in breeding, registering, selling, purchasing, exhibiting and running purebred dogs, to prevent, detect, and punish frauds in connection therewith, to protect the interests of its members, to publish an official kennel gazette, and generally to do everything to advance the study, breeding, exhibiting, running and maintenance of purebred dogs." On July 18, 1974, this Office, through then Commissioner Misael P. Vera, issued BIR ruling exempting it from income tax. In reply, please be informed that under Section 30 (C) of the Tax Code of 1997, as amended, a non-stock corporation or association organized and operated exclusively for the benefit of the members is exempt from income taxation. Accordingly, as a non-stock, non-profit association, operating for the exclusive benefit of your members, you are, therefore, exempt from tax on all revenues derived in pursuance of your purpose as such organization and used actually, directly and exclusively for the aforesaid purpose. However, you are subject to internal revenue taxes on income from other activities the conduct of which is not related to the exercise or performance of your purposes or functions. Moreover you are subject to the corresponding taxes imposed under the Tax Code of 1997, as amended, on your income derived from any of your properties, real or personal, regardless of the disposition thereof, which income should be returned for taxation. Likewise, interest income from your currency bank deposits and yield or any other monetary benefits from deposit substitute instruments and from trust funds and similar arrangements you receive, and royalties derived from sources within the Philippines are subject to the 20% final withholding tax: provided, however, that interest income you derive from a depository bank under the expanded foreign currency deposit system shall be subject to 7-1/2% final withholding tax pursuant to Section 28 (A) (7) (a), in relation to Section 57 (A), both of the Tax Code of 1997, as amended. Moreover, as a tax-exempt organization, you should file an annual information return on or before the 15th day of the 4th month following the end of its taxable year. Under Section 235 of the Tax Code of 1997, as amended, any provision of existing general and special law to the contrary notwithstanding, the books of accounts and other pertinent records of tax-exempt organizations or grantees of tax incentives shall be subject to examination by the BIR for purposes of ascertaining compliance with the conditions under which they have been granted tax exemptions or tax incentives, and their tax liabilities, if any. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. AHcDEI Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service