CCT Group of Ministries

March 11, 2009 BIR RULING [NSNP-(S30E-036) 204-09] S-30-102-2008; Dtd. 06/11/2008 CCT Group of Ministries 5F Joshua Center, 1428 Taft Avenue Ermita, Manila, Philippines Attention: Elizabeth M. Venegas Executive Officer Gentlemen : This refers to your letter dated November 14, 2008 requesting for exemption from the payment of income tax and filing of the corresponding income tax return under Section 30 of the Tax Code of 1997, as amended. DcTSHa Documents submitted to this Office disclosed that CCT Training and Development Institute (CCT-TDI) is a non-stock, non-profit educational institution, with Taxpayers Identification Number 249-256-976 duly registered with the Securities and Exchange Commission (SEC) under SEC Registration No. CN200604138 dated September 25, 2007; and that the purposes for which the corporation was formed are a) to establish and operate an educational institution or learning center which shall provide courses of study in entrepreneurship, business management, servant leadership, community governance, enterprise development (non-degree technical courses) or other similar courses subject to the laws of the Philippines; and b) to receive tuitions and miscellaneous fees, accept donations, endowments, grants, legacies and instruments/devices conformably with the existing applicable statutes. In reply, please be informed that this Office cannot yet issue the requested ruling/certificate of tax exemption. You have to prove by actual operation for at least three (3) years that you are really an organization/association exempt from income tax under Section 30 of the Tax Code of 1997, as amended. You can file the necessary annual information return instead of an income tax return on or before April 15 of each year following the start of your operation as an exempt organization as required under Section 24 of Revenue Regulations No. 2. Based on such information return, we shall conduct the necessary investigation on your activities undertaken during the period. The letter of exemption shall thereafter be issued depending upon the result of our investigation. However, CCT Training and Development Institute (CCT-TDI) shall be subject to the corresponding internal revenue taxes imposed under the Tax Code of 1997, as amended, on income derived from any of its properties, real or personal, or activity conducted for profit regardless of the disposition thereof, which income should be returned for taxation. Likewise, interest income from currency bank deposits and yield or any other monetary benefit from deposit instruments and from trust funds and similar arrangements, and royalties derived from sources within the Philippines are subject to 20% final withholding tax; provided, however, that the interest income you derive from a depository bank under the expanded foreign currency deposit system shall be subject to a final withholding tax of 7 1/2% pursuant to Section 27 (D) (1) in relation to Section 57 (A) of the Tax Code of 1997, as amended. Moreover, you are required to file on or before the 15th day of the fourth month following the end of your accounting period a Profit and Loss Statement and Balance Sheet with Annual Information Return under oath, stating your gross income and expenses incurred during the preceding period and a certificate showing that there has not been any change in your By-Laws, Articles of Incorporation, manner of operation and activities as well as sources and disposition of income. It should be understood that CCT Training and Development Institute (CCT-TDI) shall be constituted as a withholding agent for the government if it acts as an employer and any of its employees receives compensation income subject to withholding tax, or if it makes payments to individuals or corporations subject to the withholding tax provided for in Section 57 of the Tax Code of 1997, as amended. EaSCAH Finally, your books of accounts and other pertinent records shall be subject to periodic examination by revenue enforcement officers of this Bureau for the purpose of ascertaining whether you have been complying with the conditions under which you may be granted tax exemption or tax incentives and tax liability, if any, pursuant to Section 235 of the Tax Code of 1997, as amended. This ruling is being issued on the basis of the foregoing facts as presented. However, if upon investigation it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service