Exemption from the Payment of Income Tax

April 2, 1981 BIR RULING NO. 066-81 27-f 000-00 066-81 Philippine Chamber of Commerce and Industry, Inc. CCP Bldg., Magallanes Drive Intramuros, Manila Attention: Mr . Antonio A . Chuidian Acting Director-General Gentlemen : This refers to your request for exemption from the payment of income tax and the filing of the corresponding income tax return under Section 27(f) of the National Internal Revenue Code, as amended. Investigation conducted by this Office disclosed that the Philippine Chamber of Commerce and Industry, 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 as follows: (a) to foster closer relations, understanding and cooperation among the commercial and industrial sectors of the economy by unifying them into one strong and solid union for the better enhancement of economic growth and development; (b) to serve as the forum for the development of a consensus of the business community on matters of economic significance; (c) to serve as the lead organization in the formulation of mechanics leading to the unification of the entire private business sector into one single organization and (d) to provide the institutional framework for the evolvement of a "single voice" organization that will be the spokesman of the entire private business sector in all its dealings with the government; that the organization shall be maintained principally through membership dues, entrance fees, seminars/conference fees, assessments, donations, subscriptions, certification of source of origin of Philippine export; and that no part of its net income shall inure to the benefit of any private individual or member. In view thereof, this Office is of the opinion and so holds that the Philippine Chamber of Commerce and Industry, Inc., is a business league as contemplated under Section 27(f) of the National Internal Revenue Code, as amended because it is an association of persons having some common business interest and does not engage in regular business of a kind ordinarily carried on for profit, (Sec. 31 Revenue Regulations No. 2). Accordingly, it is exempt from the payment of income tax in respect of income received by it as such organization, and therefore need not file an income tax return concerning such income. However, pursuant to Section 27 of the Tax Code, as amended by P.D. No. 1457 which took effect on August 5, 1978, it is subject to the corresponding internal revenue taxes imposed under the National Internal Revenue Code on its 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 . (Revenue Memorandum Circular No. 80-78 dated August 15, 1978) Moreover, it is required to file on or before April 15 of each year a profit and loss statement and balance sheet with the annual information return under oath, stating its gross income and expenses incurred during the year and a certificate showing that there has not been any change in its By-Laws, Articles of Incorporation, manner of operation and activities as well as sources and disposition of income. cd Very truly yours, RUBEN B. ANCHETA Acting Commissioner