BIR Ruling

April 10, 1973 Mr. Mel Van Peursem Director, World Vision Relief Organization: Philippines 555 J. Nakpil St., Ermita Malate, Manila S i r : This refers to your letter dated February 21, 1973 requesting information as to whether or not American missionaries staying in the Philippines on a Temporary Visitor Visa for ten (10) months are required to pay income tax. It is represented that said "missionaries are volunteered social and churchworkers who will hold evangelistic meetings, assist in the social-economic self-help projects, and conduct Bible studies in some places of the Philippines. These projects are under the auspices of the COW (Christ the Only Way) Movement whose activities deal mostly with missionary work and as such no salary is involved. Funds to support the missionaries and their work while in the Philippines will come from benevolent friends of foreign countries? In reply thereto, I have the honor to inform you that the funds received by the American missionaries in order to support their ten (10) months stay in the Philippines doing missionary work are in the nature of allowances which are actually donated to their organization from their benevolent friends abroad. Such funds spent in religious work of which activity is exempt from income tax under Section 27(e) of the Tax Code are not considered income to the recipient. In view thereof, the American missionaries concerned need not file income tax returns declaring said funds for income tax purposes. cdta Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue