Does the Certificate of Tax Exemptions have Retroactive Effects?

Tax exemption of transactions prior to issuance of Certificate of Exemption.

Tax exemptions of cooperatives are granted by law (Article 61 and 62 of Republic Act 6938). Thus, the effectivity of the tax exemption privileges of the cooperative is the date of approval of registration by the CDA, considering that the issuance of the Certificate of Exemption by the Bureau of Internal Revenue is merely confirmatory.