VAT Ruling No. 068-01

October 11, 2001 VAT RULING NO. 068-01 109 (m) Spirit of Joy Learning Center, Inc. Blk. 8 Lot 34 Leader Street Pleasant Hill Subd., San Jose del Monte City Attention: Ms. Medelyn Ruth N. Azucena Principal/CEO M a d a m : This refers to your letter dated July 16, 2001 requesting for a ruling that Spirit of Joy Learning Center, Inc. is exempt from VAT pursuant to Section 109(m) of the 1997 Tax Code. Documents submitted show that on April 8, 1999, the Spirit of Joy Learning Center, Inc . was granted by the Department of Education, Culture & Sports (DECS), Government Recognition No. E-016 s. of 1990 for the Pre-Elementary Course. On May 10, 2001, the school was granted by the DECS Region III, Government Permit No. E-081 s. 2001 to operate Grade V (renewal Grades 1-IV) of the Elementary Course which is valid only for school year 2001-2002 and does not extend to any branch of that school whether located in the same municipality or city or in any other municipalities or cities. In reply, please be informed that pursuant to the aforecited Section 109(m) of the 1997 Tax Code, private educational institutions shall be exempt from value-added tax provided they are accredited as such either by the Department of Education, Culture and Sports or by the Commission on Higher Education. Accordingly, your gross receipts from the operations of the Spirit of Joy Learning Center, Inc. are exempt from the 10% VAT but only for the school year 2001-2002. Furthermore, this exemption does not extend to your other activities involving sale of goods and services. Very truly yours, (SGD.) EDMUNDO P. GUEVARA Deputy Commissioner (Legal and Inspection Group)