BIR Ruling [UN-071-94]

February 22, 1994 BIR RULING [UN-071-94] The Roman Catholic Archbishop of Manila 121 Arzobispo Street Intramuros, Manila Attention: Msgr . Domingo A . Cirilos, Jr . Treasurer S i r : This refers to your letter dated May 18, 1993 requesting exemption under Section 94(a) (3) of the Tax Code, as amended, of the donation made by Dolores Paterno de Tuason, for herself and in behalf of Maria Lourdes Tuason, of a parcel of land located in Sampaloc, Manila containing an area of two hundred forty four square meters and one square meters and one square decimeter (244.1) more or less covered by Transfer Certificate of Title No. 94040 of the Register of Deeds of Manila in favor of the Roman Catholic Archbishop of Manila by virtue of a Deed of Donations executed on April 18, 1990. Documents submitted show that The Roman Catholic Archbishop of Manila is a religious corporation sole, organized for the principal purpose of administering its temporalities. aisadc 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). cd Very truly yours, JAIME M. MAZA Assistant Commissioner (Legal Service)