BIR Ruling

May 25, 1976 Shrines of Mary Tours, Inc. Rm. 308 Pius XII Catholic Center 1175 U.N. Ave.,Paco, Manila Attention: Mrs . Gaudelia G . Donato President & Chairman 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 Shrines of Mary Tours, Inc. (formerly Philippine Pilgrimage Company Shrines of Mary Tours, Inc.) is a non-stock, non-profit corporation duly registered with the Securities and Exchange Commission; that the purposes for which the corporation is formed are: 1) To participate seriously and effectively in the spread of devotions to the Mother of Jesus, the Blessed Virgin Mary, as patron saint of the archipelago; 2) To undertake domestic religious tours or pilgrimages specifically in Greater Manila area for school groups, Catholic organizations and devotees coming from the provinces; 3) To gather and disseminate information pertaining to the various shrines of Mary throughout the Philippines and make it known to new devotees through a catholic guide manual with photographs and through a MARIAN LIBRARY & GALLERY in the near future; 4) Initially localized in Greater Manila area and then eventually to manage pilgrimages throughout the Philippines with the expansion of this undertaking; 5) To donate to the shrine churches in their social work for the sick, the poor and the needy; 6) To boost Tourism Industry by encouraging travel among catholic Filipinos and within their own country; that the place where the principally office of the corporation is to be established is at 1175 U.N. Avenue, Pius XII Catholic Center Building, Paco, Manila; that the term for which said Corporation shall exist is fifty (50) years from and after the date of incorporation; that the Corporation shall be maintained by dues, quotas from its members, donations, contributions from its members and benefactors, and the Marian pilgrimage tours shall be conducted as a source of funds for the association; and that no part of its net income inures or accrues to the benefit of any private individual or member. In view thereof, since that Corporation falls within the purview of a corporation organized and operated exclusively for religious purposes, pursuant to Section 27(e) of the Tax Code it is exempt from the payment of income tax on income earned by it as such corporation and, therefore, need not file an income tax return covering such income. 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. And even if no taxable income is earned, it should file on 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; and c) a certificate attesting that there has not been any change in its By-Laws, Articles of Incorporation, and its activities and manner of operation. acd Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3