BIR Ruling

June 14, 1976 Philippine Association For Theological Education By Extension, Inc. 1823 E. Rodriguez Sr. Avenue Cubao, Quezon City Attention: Mr . Robert L . Samms Board Chairman/President Gentlemen : This refers to your request for exemption from the payment of income tax and filing of the corresponding income tax return under Section 27(e) of the Tax Code. Investigation conducted by this Office disclosed that the Philippine Association For Theological Education By Extension, 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: a) To develop and promote theological education by extension among evangelicals in the Philippines; b) To purchase, own, lease, occupy invest, use or hold such real and personal properties as may be convenient and proper to further the purposes for which this organization is formed; and c) In general, to do all and everything necessary, suitable and proper for the accomplishment of the purposes hereinabove set forth, and to do every other act or thing necessary, incidental, or pertaining to, or growing out of, or connected with the aforesaid powers or purposes, or any part thereof, to the extent allowed by law; that the Corporation shall be maintained by donation and contributions mainly from members and other individuals, churches and mission groups which are sympathetic to the purposes and objectives of the corporation; 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. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN 1456-040-3