BIR Ruling [UN-206-95]

June 7, 1995 BIR RULING [UN-206-95] Pamplona Evangelical Church (United Church of Christ in the Philippines) 3 Menandro Street, Balagtas Pamplona, Las Pias, Metro Manila Attention: Mr . Bonifacio Bayhon Gentlemen : This refers to your letter dated April 28, 1995 requesting exemption under Section 94(a)(3) of the Tax Code, as amended, of the donation made by Mr. Bonifacio Bayhon of a parcel of land located at No. 3 Menandro Street, Balagtas Subdivision, Pamplona 1, Las Pias, Metro Manila, containing an area of two hundred twenty seven (227) square meters, covered by Transfer Certificate of Title No. T-15070 of the Registry of Deeds of Las Pias, Metro Manila, in favor of Pamplona Evangelical Church, Inc. cdtech Documents submitted show that the Pamplona Evangelical Church, Inc. is a non-stock, non-profit religious corporation. 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, an 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 P10.00 imposed under Section 188 of the same Code. [BIR Ruling No. 94(a) (3) 301-92-452-93 dated November 19, 1993]. Very truly yours, ALICIA P. CLEMENO Assistant Commissioner (Legal Service)