REVENUE MEMORANDUM CIRCULAR NO. 123-2024 issued on November 15, 2024, clarifies the validity of a Certificate of Tax Exemption (CTE) issued to certain corporations. Pursuant to prevailing laws and revenue issuances, the three (3) year validity period provided in Revenue Memorandum Order (RMO) No. 38-2019 shall not apply to the CTE of the following corporations:

         a. Non-stock and non-profit educational institutions as provided under Section 30 (H) of the Tax Code and RMO No. 044-2016;
     b. Homeowners’ Association as provided under Republic Act (RA) No. 9904 and Revenue Memorandum Circular (RMC) No. 09-2013, as amended and
          c. Non-stock savings and loan association as provided under RA No. 8367 and RMC No. 9-2016.

The 3-year validity period shall not apply to the issued CTE, or otherwise known as Certificate of Qualification, of an employees’ retirement benefit plan created under RA No. 4917 and Revenue Regulations (RR) No. 1-68, as amended by RR No. 1-83. 

Therefore, issued CTEs of the above-enumerated corporations and employees’ retirement benefit plan shall remain valid and effective unless recalled or revoked by the BIR for valid grounds. If there are material changes in the character, purpose or method of operation of the corporation or in the provisions of the employees’ retirement benefit plan which are inconsistent with the basis for Income Tax exemption, the CTE shall be subject to revalidation.