BIR Ruling [UN-273-95]

July 25, 1995 BIR RULING [UN-273-95] Shrine of the Holy Face of Jesus Sisters of Perpetual Adoration, Inc. 1111 R. Hidalgo Street, Quiapo Manila Attention: Mother Ma . Pierina, HFJ Superior Gentlemen : This refers to your letter dated June 30, 1995 requesting exemption under Section 94 (a) (3) of the Tax Code as amended, of the donation made by Rufina Development Corporation of a parcel of land located in Quiapo, Manila containing an area of two hundred fourteen square meters and thirty decimeters (214.30 sqm.) more or less, covered by Transfer Certificate of Title No. 93412 of the Registry of Deeds of Manila, in favor of the Shrine of the Holy Face of Jesus Sisters of Perpetual Adoration, Inc. cdll Documents submitted show that the Shrine of the Holy Face of Jesus of Sisters of Perpetual Adoration, Inc. is a non-stock, non-profit religious corporation sole. 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 188 of the same Code, as amended. (BIR Ruling Nos. 301-92 dated October 27, 1992 and 452-93 dated November 19, 1993). liblex Very truly yours, ALICIA P. CLEMENO Assistant Commissioner (Legal Service)