Tax Exemption Granted to "International Rice Research Institute" (IRRI)

February 23, 1960 BIR RULING NO. 059-60 The Director The Rice Research Foundation 703 Trinity Building San Luis, Manila S i r : Reference is made to your letter of even date, stating that Foundation will soon be incorporated and known as the "International Rice Research Institute" (IRRI). With said letter were submitted copies of: (1) the letter dated September 16, 1959 of the Office of the President of the Philippines, informing of the approval by the Cabinet of the proposal to establish a Rice Research Foundation in the Philippines; (2) the Memorandum of Understanding signed on December 9, 1959 by and between the Government of the Philippines, on the one hand, and the Presidents of the Rockefeller Foundation and Ford Foundation, on the other; (3) the draft of the articles of incorporation of the IRRI. You stated that in order for the aforenamed Foundations to make any grant to the IRRI, it is necessary to present a letter from this Office certifying that the IRRI is exempt from the Philippine income tax. In answer thereto, I have the honor to inform you that, based on the copies of the documents submitted with your letter under reply, this Office is of the opinion and so holds that the IRRI is exempt from the income tax by virtue of section 27(e) of the National Internal Revenue Code, it appearing that it is a non-stock, non-profit corporation to be organized and operated exclusively for scientific purposes, provided, however, that the income of whatever kind and character from any of its real or personal property or from any activity conducted for profit, if any, regardless of the disposition made of such income, shall be subject to tax. aisadc Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue