Professional Documents
Culture Documents
Gentlemen :
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3. To initiate, stimulate, support and conduct activities that will
enhance attainment of the corporation's interests, goals and objectives;
It is composed of physicians and child protection units from all over the
Philippines dedicated to educating multi-disciplinary professionals such as physicians,
social workers, lawyers, police and the judiciary in the integrated management of abused
and neglected children. As part of its professional education thrust, CPU Net will host
the 7th ISPCAN Asian Regional Conference to be held at the Hotel Philippine Plaza
from September 23 to 26, 2007 entitled "AKO PARA SA BATA" (I am for the Child).
This is a biennial Asian conference which will be held for the first time in the
Philippines with delegates from various professional, governmental and
non-governmental organizations of different countries throughout Asia, Europe,
Australia and America to discuss the following issues:
CPU Net has prepared simultaneous symposia and workshops that would benefit
the different disciplines needed in addressing the above child abuse and neglect issues.
Speakers from the Philippines as well as other Asian countries, the US, Europe and
Australia will share their expertise and experiences on what works and what can be
applied in different cultural settings. Moreover, it has tapped the ISPCAN executive
councilors, the US Office of Juvenile Justice and Delinquency Prevention (OJJDP),
Child Rights Education for Professionals (Cred-Pro), ECPAT and the Philippine Judicial
Academy (PHILJA), among others, to conduct workshops for specific disciplines. The
Department of Social Welfare and Development (DSWD) is a major partner of CPU-Net
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in the Conference.
CPU Net has solicited various donations from persons, corporations and
organizations, here and abroad, who have given the aggregate amount of Four Million
Six Hundred Forty Thousand Pesos (PhP4,640,000) all of which are intended to defray
the expenses that will be incurred before and during the Conference. Most of the
expenses involve sponsorship of invited international speakers and registration and
support of Asian and local participants. CPU Net expects that Six Million Five Hundred
Thousand Pesos (PhP6,500,000) more will be needed to fully cover these expenses.
CPU Net is currently in the process of securing its accreditation with the
Philippine Council for NGO Certification, Inc. (PCNC).
On the issue of deductibility of donations from the gross income of the respective
donors, Section 34 (H) (2) (C) of the Tax Code of 1997 provides that donations to an
accredited non-government organization (NGO), which means a non-profit domestic
corporation or association organized and operated exclusively for scientific, research,
educational, character building and youth and sports development, health, social welfare,
cultural or charitable purposes or a combination thereof, no part of the net income of
which inures to the benefit of any private individual, shall be deductible in full from the
taxable business income of the donor depending on the donee's compliance with the
level of administrative expense and utilization requirements. EIAaDC
In case of failure on the part of the accredited NGO to comply with the level of
administrative expense and utilization requirements, its donors shall be entitled only to
the limited deductions in an amount not in excess of 10% in the case of an individual,
and 5% in the case of a corporation, of the donor's taxable income derived from trade,
business or profession as computed without the benefit of Section 34 (H) of the Tax
Code of 1997, as provided for under Section 34 (H) (1) of the same Tax Code.
Donations, contributions or gifts actually paid or made within the taxable year to
an accredited NGO shall be allowed full deductibility on the taxable year it was incurred
pursuant to Section 34 (H) (2) (C) of the Tax Code of 1997 (BIR Ruling No.
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DA-124-2004, April 20, 2004 and BIR Ruling No. S30-016-2004 dated May 6, 2004).
In relation to the above regulations, Sections 5 and 6 of Rev. Regs. No. 13-98
implementing R.A. No. 8424 specifically, Section 34 (H) thereof relative to the
deductibility of contributions or gifts actually paid or made to accredited donee
institutions in computing taxable income, states that —
It is clear from the foregoing that the only obligation of the donee for every
donation or gift it receives is to issue in triplicate the proper COD within thirty (30) days
after the receipt of the donation. It should furnish the donor and RDO having jurisdiction
over it (donee) one copy each of the COD and keep the last copy for itself.
On the part of the donor and for purposes of full deductibility from his/its taxable
business income, the donor should be the one to notify within thirty (30) days from
receipt of the COD, the RDO where his/its place of business is located, of donations
worth Fifty Thousand Pesos (P50,000) which he/it made and have the COD stamped at
the concerned RDO.
In view of the foregoing, CPU Net must first be accredited with the PCNC which
has been duly designated by the Secretary of Finance as the Accrediting Entity pursuant
to Memorandum of Agreement dated January 29, 1998 executed by and between the
Secretary of Finance and PCNC's Interim Chairman in order that donations to it can be
exempt from donor's tax and its donors can claim full deductibility from their respective
taxable business income.
This ruling is being issued on the basis of the foregoing facts as represented.
However, if upon investigation, it will be disclosed that the facts are different, then this
ruling shall be considered null and void.
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