BIR Ruling [UN-244-95]

July 3, 1995 BIR RULING [UN-244-95] Atty. Jose P. Garcia 322 U.P. Bliss Diliman, Quezon City S i r : This refers to your letter dated March 12, 1995 requesting exemption in behalf of your client, the Local Superior of the Sisters Adorers of the Blood of Christ, Inc., from the payment of donor's tax and documentary stamp tax. cdtech It is represented that the Superior General of the Religious of the Virgin Mary, Inc. donated four (4) parcels of land described as follows: TCT Number Location Area (Sqm.) 43440 Tandang Sora Quezon City 425 80889 do 482 97361 do 400 97362 do 422; of the Land Registry of Quezon City, Metro Manila, together with all the buildings and improvements existing thereon, in favor of your client, the Local Superior of the Sisters Adorers of the Blood of Christ, Inc., a religious corporation sole duly registered with the Securities & Exchange Commission under Registration No. ANO91-196830 dated October 14, 1991. 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 P10.00 imposed under Section 188 of the same Code. [BIR Ruling No. 94 (a)(3) 306-92-452-93 dated November 19, 1993]. Very truly yours, ALICIA P. CLEMENO Assistant Commissioner (Legal Service)