BIR Ruling

September 15, 1977 Buddha's Eternal Mercy Center, Inc. 19 Northern Polythec University Hill Malabon, Metro Manila 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. Investigation conducted by this Office disclosed that the Buddha's Eternal Mercy Center, Inc., is a non-stock, non-profit corporation duly registered with the Securities and Exchange Commission; that the primary purposes. for which the corporation, is formed are: to carry on in any and every way, and to impart without distinction as to sect, creed or race the teachings of Buddhism of SAKKYUMUNI BUDDHA and to foster and promote the spirit of brotherhood among its members; to teach individuals the development and redevelopment of character in order to enjoy a happy and serene life through the religion of Buddhism as taught by SAKKYAMUNI BUDDHA; to teach individuals escapements from man's eternal sufferings in birth, age, poverty and death so as to enjoy a prosperous life of serenity; to provide, through instructions, the true interpretations by SAKKYAMUNI BUDDHA of the Buddhism religion, and to that end, conduct and maintain schools or other institutions of learning or instruction, temples and other places of worship; to operate radio stations, television stations, engage in all other possible effective means of media which would aid in the widespread circulations of such teachings; To conduct surveys and conferences on subjects which this corporation and/or its members may be interested in; to engage in the publication of newspapers and periodicals and other printed matters covering the religion of Buddhism as taught by SAKKYAMUNI BUDDHA, that the corporation shall be maintained mainly by donations contributions, gifts, devices and bequests from the members and that no part of its net income shall inure or accrue to the benefit of any individual members. In view thereof, this Office is of the opinion and so holds that Buddha's Eternal Mercy Center, Inc., 19 Northern Polythec, University Hill Malabon, Metro Manila falls within the purview of an organization organized for purely religious purposes as contemplated by Section 27(e) of the Tax Code. Accordingly, it is exempt from the payment of income tax. It is however, 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 made of such income. Moreover, it is required to file on or before April 15 of each year a profit 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. Very truly yours, CONRADO P. DIAZ Acting Commissioner of Internal Revenue TAN-D2567-D1025-A-2