September 9, 2009
BIR RULING [NSNP-(S30H-094) 571-09]
Sec. 4 (3) Art. XIV, 1987 Constitution; ENPS-057-2007
Sapalo Velez Bundang & Bulilan Law Offices
11th Floor, Security Bank Centre
6776 Ayala Avenue, Makati City
Attention: Atty. Romeo H. Duran
and
Atty. Alexius P. Tang
Gentlemen :
This refers to your letter dated June 29, 2009 requesting, on behalf of the FOOD FOR HUNGRY MINDS SCHOOL, INC., for tax exemption pursuant to paragraph 3, Section 4 Article XIV of the 1987 Constitution.
Documentary evidence submitted disclosed that the FOOD FOR HUNGRY MINDS SCHOOL, INC. is a non-stock, non-profit educational institution duly registered with the Securities and Exchange Commission (SEC) under SEC Reg. No. CN200405694 dated April 13, 2004; and that it is duly recognized by the DEPED with Government Recognition No. E-011, series of 2007.
In reply, please be informed that paragraph 3, Section 4, Article XIV of the 1987 Constitution provides, viz.:
"(3) 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. . . ."
The exemption under Section 4 (3), Article XIV of the...