Donations to Foreign Missionaries - Tax-Exempt

February 11, 1993 BIR RULING NO. 062-93 DONATIONS TO FOREIGN MISSIONARIES TAX-EXEMPT 21 330-92 062-93 Presbyterian Church of the Philippines, Inc. A.C.A. P.O. Box 595 Quezon City This refers to your letter dated October 22, 1992 requesting a ruling that donations received by your foreign missionaries are not subject to income tax. cd It is represented that your church invites enlightened devotees from here and abroad to join in your missionary work on a voluntary basis; that there is no monetary compensation or salary for their services except the subsidy or pension allowance to cover their necessary personal subsistence or temporal needs; that before they are allowed to conduct missionary work, they are first required by the church to take an oath that they will give their entire life to the service of God and his people; that the church in Korea is able to subsidize all their activities including their personal subsistence through donations; and that there is definitely no employer-employee relationship between the missionaries and the church. In reply, please be informed that since the various financial support being received by the foreign missionaries are not compensation and/or salary but donations given them prior to their coming to the country, and that said funds are merely coursed through your church in the Philippines for the account of the foreign missionaries, said financial support are not subject to Philippine income tax. It should be understood, however, that if upon investigation, the facts as represented are found to be different, this ruling shall be null and void. cdta JOSE U. ONG Commissioner of Internal Revenue