BIR Ruling No. 113-82

April 15, 1982 BIR RULING NO. 113-82 027-f 000-00 113-82 Manila Stock Exchange MSE Building, Prensa Street Cor. Muelle de la Industria Binondo, Manila Attention: Mr . Jose C . Cervantes Gentlemen : This refers to your letter dated October 15, 1980 requesting 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 Manila Stock Exchange, is a non-stock, non-profit corporation duly registered with the Securities and Exchange Commission; that the purposes for which the Exchange is formed are; to furnish rooms and other facilities for the convenient transaction of the business of its members; to maintain high standards of commercial honor and integrity among its members, and to promote and inculcate just and equitable principles of trade and business; and that the Exchange is maintained primarily through entrance fees, monthly dues and assessments, initiation fees, listing fees, and from fines and penalties being imposed to members; and that no part of its net income inures to the benefit of any private individual or member. It has been held that if the organization's primary purposes is to provide services or facilities for transacting business to individuals or a limited class, it is not an exempt business league. Thus a stock or commodity exchange is not a business league. [34 Am. Jur. 2d p. 687 (1976 ed)] cdtech In view thereof, the Manila Stock Exchange, cannot be considered an exempt business league within the purview of Section 27(f) of the Tax Code. Consequently, it should file an income tax return and pay income tax on its net income. Moreover, the Manila Stock Exchange is subject to business taxes. Very truly yours, RUBEN B. ANCHETA Acting Commissioner