BIR Ruling [UN-068-94]

February 18, 1994 BIR RULING [UN-068-94] The Roman Catholic Archbishop of Manila 121 Arzobispo Street Intramuros, Manila Attention: Msg . Domingo A . Cirilos, Jr . Treasurer S i r : This refers to your letter dated August 6, 1993 requesting exemption under Section 94 (a) (3) of the Tax Code, as amended, of the donation made by the SIKATUNA VILLAGERS ASSOCIATION, INC. represented by its president, Mr. Dominador M. De Guzman, of a parcel of land located in Quezon City containing an area of five hundred fifty seven square meters and thirty square decimeter (557.30) more or less covered by Transfer Certificate of Title No. RT-59838 (357223) of the Register of Deeds of Quezon City in favor of the Roman Catholic Archbishop of Manila by virtue of a Deed of Donation executed on August 6, 1993. Documents submitted show that The Roman Catholic Archbishop of Manila is a religious corporation sole organized for the principal purpose of administering its temporalities. 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 gift shall be used by the donee for administration purposes. Moreover, the aforesaid Deed of Donation is not subject to the documentary stamp tax prescribed under Section 196 of the Tax Code, as amended, but only to the documentary stamp tax of P3.00 imposed under Section 188 of the same Code (BIR Ruling No. 301-92). aisadc Very truly yours, JAIME M. MAZA Assistant Commissioner (Legal Service)