BIR Ruling

March 13, 1973 Sr. M. Titiana Dal Masetto Sisters Disciples of the Liturgical Apostolate 949 Josefa Llanes Escoda Ermita, Manila M a d a m : This refers to your letter dated March 7, 1973 requesting that your congregation be exempted from the payment of internal revenue tax on business for the sale of sacred vestments, linens and materials for the holy sacrifice of the mass and other religious items which aid to beautify the church. It appears that your congregation is a non-profit organization or is not engaged is commercialism; that it has a three-fold apostolate work: adoration of the Blessed Sacrament, service to the priesthood and liturgy; that in your liturgical apostolate, your congregation makes sacred vestment, linens and materials for use in the holy sacrifice of the mass; that your congregation prepares and distributes whatever aids divine worships and to beautify the church; and that in order to educate the faithful to the proper use of liturgical furnishings with appropriateness and dignity a center has to be established or built, wherein those liturgical articles could be displayed and be visited and seen by the faithful to experience divine realities through sacred arts and beauty. In reply, I have the honor to inform you that under the foregoing fact, it is the opinion of this Office, as it hereby holds that the distribution or sale of these liturgical articles to its faithful followers are exempt from the payment of internal revenue tax on business in pursuance to the constitutional provision on the free exercise and enjoyment of religious profession and worship (Section 8 Art. IV of the new Constitution). Furthermore, it has been held that the sale of religious articles by a religious organization primarily in the furtherance of its religious activities may not be considered a business. (American Bible Society vs. City of Manila, 101 Phil. 386). cdta Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue