Request for Exemption from the Payment of Income Tax and the Filing of the Corresponding Income Tax Return

April 4, 1994 BIR RULING NO. 082-94 21 209-90 082-94 Gospel Fellowship Association Box 120 U.P. Quezon City Attention: Ms . Brenda Garren Gentlemen : This refers to your letter dated March 5, 1993, requesting exemption, in behalf of your foreign missionaries, from the payment of income tax and the filing of the corresponding income tax return. It is represented that the Gospel Fellowship Association is a non-stock, non-profit religious corporation organized under the laws of the State of Tennessee, U.S.A. and licensed to perform within the Philippines its evangelistic ministry on December 11, 1981; that it has foreign missionaries assigned throughout the country; that these foreign missionaries raised their financial support prior to their coming to the country from contributions, donations, gifts, pledges, in cash or check from their friends, churches and relatives abroad; that the foreign funds are coursed through the Gospel Fellowship Association's main office in Greenville, S.C. in the U.S.A. and then sent to the missionaries based in the Philippines through Boston Bank, Diliman, Quezon City Branch. In reply thereto, please be informed that since the financial support being received by the 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 the Gospel Fellowship Association for the account of the foreign missionaries, said financial supports are not, therefore, subject to Philippine income tax. Accordingly, these foreign missionaries need not file income tax returns in the Philippines. Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue