BIR Ruling

December 17, 1976 Marikina Santo Nio Temple, Inc. Room 354 Wellington Bldg. Plaza Calderon, Binondo, Manila Attention: Miss Virginia Usabel Chairman, Board of Trustees Gentlemen : This refers to your request for exemption from the payment of income tax and the filing of the corresponding income tax return under Section 27(e) of the Tax Code. aisa dc Investigation and documentary evidence submitted to this Office disclosed that the Corporation is a non-stock, non-profit religious corporation duly registered with the Securities and Exchange Commission; that the purposes for which the Corporation is formed is for the administration of its temporalities and for the management of its properties; that the corporation is maintained by membership fees and by donations from its members and officers which are used exclusively for the needs of its chapel; and that no part of its net income inures or accrues to the benefit of any member or individual. In view thereof, that corporation falls within the purview of an association organized and operated exclusively for religious purposes, pursuant to Section 27(e) of the Tax Code, and therefore, exempt from the payment of income tax on income earned by it as such corporation. However, it is subject to income tax on income derived from any of its properties real or personal, or any activity conducted for profit, regardless of the disposition thereof, which income should be returned for taxation. If it did not earn such taxable income it need not file an income tax return. However, even if the religious corporation has not earned any taxable income, it should file or before April 15 of each year an annual information return, stating under oath its gross income and the sources thereof and the expenses incurred during the preceding year, attaching thereto a) a profit and loss statement; b) a balance sheet; c) a certificate stating that there has not been any change in its By-Laws, Articles of Incorporation, and its activities and manner of operation. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3