BIR Ruling

July 10, 1973 Atty. Amando K. Gaitos Mezzanine Floor, Del Mundo Bldg. 2121 Taft Avenue, Manila S i r : This refers to your letter dated January 11, 1973, requesting exemption in behalf of your client, the Jesus People Philippines, Inc., 170 R. Fernandez St., San Juan Rizal from the payment of income tax and filing of the corresponding income tax return under Section 27 (e) of the Tax Code. acd It is represented that the Jesus People Philippines Inc., (hereinafter referred to as the corporation) was established and organized as a non-stock and non-profit corporation duly registered with the Securities and Exchange Commission; that the purposes for which the corporation was formed are: to establish and maintain indigenous, autonomous churches, where Christ is exalted and His Gospel is propagated throughout the Philippines; to establish, maintain and conduct schools for religious education; to train, license, ordain and send out ministers thus assisting the ministry and providing recognition in all matters in which ministerial recognition may become necessary to protect liberties by the Constitution of the Republic of the Philippines; to further other religious, benevolent and charitable work such as supporting the opening of new churches of like precious faith; meanwhile, upholding a high Bible Standard of holiness; that at present, the corporation had organized religious seminars where Christian beliefs are taught including a course on how to fight drug addiction; that it has in fact rendered relief work during the height of the flood in Central Luzon and had installed four water barrels for fire prevention aids in Barrio Magsaysay; that the corporation is maintained and supported by contributions and donations from its members and friends; and that no part of its net income inures to the benefit of any private individual. Based on the foregoing representations, this Office is of the opinion and so holds that the Jesus People Philippines Inc., 170 R. Fernandez St. San Juan, Rizal falls within the purview of a corporation or association organized and operated exclusively for religious, educational and charitable purposes as contemplated under 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 from any activity conducted for profit, regardless of the disposition made of such income. If it has not earned any taxable income, it is also exempt from the filing of income tax returns. However, the corporation 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. This Office may however, revise or modify this ruling if upon investigation, it will appear that the facts are different from those upon which the ruling is predicated. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN 1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR"