Financial Support Received by Foreign Missionaries from Abroad are Not Subject to Philippine Income Tax

April 3, 1991 BIR RULING NO. 054-91 21 194-90 054-91 Gentlemen : This refers to your letter dated February 23, 1991 requesting confirmation of your opinion that the donated financial support received by the Evangelical Free Church of America (EFCA) foreign missionaries from abroad are not subject to Philippine income tax. It is represented that EFCA is a duly registered foreign corporation licensed to do business in the Philippines; that it is a non-stock, non-profit religious corporation with office in the Philippines located at Room 206, 2nd Floor, Strata 200 Bldg., Emerald Ave., (Ortigas Complex) Pasig, Metro Manila; that at present, it has about forty-two (42) foreign missionaries from America, Canada and Germany throughout the Philippines who are engaged in various religious activities, such as Evangelism and Church Planting, Theological Training and other Ministries; that its said foreign missionaries raised their financial supports prior to their coming to the Philippines from friends, relatives and churches, who may give in cash, cheques or more pledges designated specifically for the individual EFCA foreign missionary who will serve in the Philippines; and that these funds are normally coursed through the EFCA in the U.S.A. or the Evangelical Free Church of Germany and then remitted to the EFCA in the Philippines, to the account of the foreign missionary concerned. In reply, please be informed that since the financial supports being received by the EFCA Foreign Missionaries are not compensation and/or salary but donations which were given to them prior to their coming to the country; and that the funds are merely coursed through EFCA in the U.S.A. or the Evangelical Free Church of Germany home offices of said EFCA Foreign Missionaries and then remitted to the EFCA in the Philippines for the account of the foreign missionary concerned, said financial supports are not, therefore subject to Philippine income tax returns in the Philippines. (BIR Ruling Nos. 54-90, 184-90 and 209-90) cdti Very truly yours, (SGD.) JOSE U. ONG Commissioner