July 6, 2009
BIR RULING [NSNP-(S30H-077) 426-09]
Section 27 (D) (1); ENPS-006-2003
St. Mary's Integrated School, Inc.
Sta. Maria, Pangasinan
Attention: Elena O. Songcuan
Directress
Gentlemen :
This refers to your letter dated May 22, 2009, requesting a Certificate of Tax Exemption being a non-stock, non-profit educational institution pursuant to Section 4 (3), Article XIV of the 1997 Philippine Constitution.
Documents submitted disclosed that St. Mary's Integrated School, Inc., with TIN: 006-150-725, is a non-stock, non-profit educational institution registered with the Securities and Exchange Commission (SEC) on July 14, 2003, bearing SEC Registration No. CN 2003 14049; that it was duly issued by the Department of Education — Region 1, a Government Recognition (R-1) No. SE-019, S. 2003 for the Basic Education Curriculum effective as of School year 2004-2005.
In reply, please be informed that paragraph 3, Section 4, Article XIV of the 1987 Constitution provides, viz.:
"All revenues and assets of non-stock, non-profit educational institutions used actually, directly and exclusively for educational purposes shall be exempt from taxes and duties."
A non-stock, non-profit educational institution is exempt from tax on all revenues derived in pursuance...