October 14, 2009
BIR RULING [NSNP-(S30H-108) 644-09]
par. 3, Sec. 4 Art. XIV, 1987 Constitution
Immaculate Heart of Mary Academy, Inc.
Madrid Blvd. Zone II, Pinamalayan, Oriental Mindoro
Attention: Ms. Nilda Jandusay
Gentlemen :
This refers to your letter dated September 25, 2009 requesting for tax exemption as a non-stock, non-profit educational institution pursuant to Section 4 (3), Article XIV of the 1997 Philippine Constitution. TDCcAE
Documentary evidence submitted disclosed that Immaculate Heart of Mary Academy, Inc. with Tax Identification Number 004-176-524 is a non-stock, non-profit educational institution duly registered with the Securities and Exchange Commission (SEC) under SEC Reg. No. 6508 dated December 1, 1951 and further amended on March 18, 1980 and that it is duly recognized by the Department of Education in accordance with Government Recognition No. 315 Series of 1947.
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),...
