BIR Ruling

February 27, 1968 Messrs. Sycip, Gorres, Velayo and Co. P.O. Box 589, Manila Attention: Mr . B . V. Abela S i r : This refers to your letter dated February 14, 1968 requesting exemption of the Orient Airlines Research Bureau from the payment of income tax and the filing of the corresponding income tax return under Section 27(f) of the Tax Code. It is represented that the Orient Airlines Research Bureau (OARB) for short) was established and organized as a non-stock, non profit association on September 30, 1966. The purposes of which OARB was organized are to accelerate the development of air commerce in the area in the interest, safety and convenience of the traveling public and the member airlines; to serve as a common forum for the articulation of the member's views on matters and problems of common interest and concern to the members; and to foster closer cooperation among themselves, eliminate ruinous competition, and bring about an atmosphere conducive to the individual and collective growth of air commerce in the region. The OARB is financed and maintained by means of the membership fees, dues, assessments and contributions of its members; and that no part of its net income inures to the benefit of any of its members. In view of the foregoing, this Office is of the opinion and so holds that the Orient Airlines Research Bureau is exempt from the payment of income tax and the filing of the corresponding income tax return under Section 27(f) of the Tax Code. However, it is required to file on or before April 15 of each year, a profits and loss statement and balance sheet with the annual information return under oath, stating its gross income and expenses incurred during the preceding year, and a certificate showing that there has not been any substantial change in its By-Laws, Articles of Incorporation, manner of operation and activities as well as sources and disposition of income pursuant to Revenue Regulations No. 7-64, dated November 4, 1964. lexlib This Office may, however, reverse or modify this ruling, if upon investigation, it will appear that the facts are different from those represented. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue