BIR Ruling [UN-158-95]

April 12, 1995 BIR RULING [UN-158-95] Work of Mary or Focolare Movement For Men, Inc. 4800 Valenzuela Street Sta. Mesa, Manila Attention: Mr . Giacomo Pellizzari National Director Gentlemen : This refers to your letter dated March 17, 1995 requesting exemption under Section 94 (a)(3) of the Tax code, as amended, of the donations made by Ona Real Estate Corporation of a parcel of land located in Quezon City, containing an area of Ten Thousand One Hundred Twenty (10,120) square meters, covered by Transfer Certificate of Title No. 90001 of Quezon City, in favor of the Work of Mary or Focolare Movement For Men, Inc. cdta Documents submitted show that the Work of Mary or Focolare Movement For Men, Inc. is a non-stock, non-profit religious corporation organized for purposes of organizing meetings and missions to spread the Word of God specially among those people who live far from the Church and a Christian way of life; and to promote and organized large gatherings once a year called "Mariapolis." 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 no 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 P10.00 imposed under Section 100 of the same Code [BIR Ruling No. 94 (a)(3) 301-92-452-93 dated November 19, 1993]. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, the facts turned out to be different, then this ruling shall be considered null and void. Very truly yours, ALICIA P. CLEMENO Assistant Commissioner (Legal Service) By: ALICIA L. TOMACRUZ Head, Revenue Executive Assistant (Legal Service)