Skip to content

8box Solutions Inc.

4_20230710_150500_0001

Contact Number: 09369340340
Email: sales@8box.solutions

REVENUE MEMORANDUM CIRCULAR NO. 64-2013 issued on October 1, 2013 circularizes the revocation of BIR Ruling No. NSNP-(S30C-028) 726-09 granting Income Tax exemption to the Philippine Canine Club Incorporated (PCCI) under Section 30 (C) of the Tax Code of 1997.

     PCCI does not appear to operate as a society, order, or association operating exclusively for the benefit of its members, such as a fraternal organization operating under the lodge system or mutual aid association. Neither is it organized as a nonstock corporation providing for the payment of life, sickness, accident, or other benefits exclusively to the members of such society, order, or association, or nonstock corporation or their dependents.

     Originally, the Certificate of Tax Exemption granted to PCCI under Section 26 (H) of Presidential Decree No. 1158 refers to a club organized and operated exclusively for pleasure, for recreation, and other non-profitable purposes. However, said provision of the law was intentionally omitted when Republic Act No. 8424 also known as the “Tax Code of 1997” was enacted. Therefore, the income of club organized and operated exclusively for pleasure, for recreation, and other nonprofitable purposes, from whatever source, including but not limited to membership fees, assessment dues, rental income and service fees are subject to Income Tax.

     Furthermore, an investigation conducted by the Special Investigation Division shows that PCCI failed to remit Value-Added Tax (VAT) from taxable years 2004 to 2012. Under BIR Ruling No. NSNP-(S30C-028) 726-09 dated 20 November 2009, PCCI was never granted exemption from VAT. Section 105 of the Tax Code of 1997 provides that even non-stock, non-profit organization or government entity is liable to pay VAT on the sale of goods or services.

     Based on the said premises, BIR revokes BIR Ruling No. NSNP-(S30C-028) 726-09 granting tax exemption to PCCI as the same has no legal basis.