Under P.D. No. 507, "Charitable Institutions" Do Not Include Religious Orders or Societies

January 15, 1975 BIR RULING NO. 001-75 Under P.D. No. 507, "Charitable institutions" do not include religious orders or societies . This refers to your letter dated November 14, 1974 requesting interpretation of the provision of Presidential Decree No. 507 as to whether or not the phrase "Charitable institutions" includes religious orders or societies, like the Society of the Divine Word or Society of Jesus, dedicated to parochial, religious works and catechistical instructions as well as educational institutions which are non-profit and churches, like the Roman Catholic Church or any part or subdivision thereof. cdta In reply, I have the honor to inform you in the negative. Quoted hereunder in Section 3(c) of Revenue Regulations No. 8-74 dated September 24, 1974 implementing Presidential Decree No. 507: "xxx xxx xxx "(c) A charitable institution is generally one that exists to carry out a purpose recognized in law as charitable, such as the relief and comfort of the poor, the sick and the afflicted, and, in general, to promote the welfare of others in need, no part of the net income of which inures to the benefit of any private individual." Obviously, under the above-quoted provision, religious and educational institutions are not embraced within the term "Charitable institutions". While religious and educational institutions may be undertaking charitable activities, such undertakings are merely incidental to the purpose for which they were organized which is religious or educational, as the case may be. Furthermore, the Decree only enumerates social welfare, cultural and charitable institutions. If the Decree intended to include religious and educational institutions, it would have so stated clearly in the enumeration. cdt