Financial Support Received by Foreign Missionaries are Not Subject to Philippine Income Tax

August 20, 1991 BIR RULING NO. 159-91 21 48-91 159-91 Gentlemen : This refers to your letter dated April 25, 1991, requesting for a ruling as to whether the financial support received by the foreign missionaries of your client, New Tribes Mission of the Philippines, Inc. is subject to income tax or not. It is represented that New Tribes Mission of the Philippines, Inc. (New Tribes) is a non-stock, non-profit corporation organized and existing under the laws of the State of Florida, U.S.A. and licensed to do business in the Philippines on April 29, 1982 under Reg. No. 1023 of the Securities & Exchange Commission; that New Tribes assigned missionaries all over the archipelago to various missions set up in Luzon and Mindanao to meet the spiritual needs of the cultural minorities and tribal peoples living in remote places; that these missionaries do not received any compensation in the Philippines but they derive financial support from funds in the form of cash, cheques and pledges raised from friends, relatives and churches abroad, prior to their arrival in the Philippines; that these funds are received and disbursed through the Ministry Expense Reimbursement Control Program of the Mother Corporation in the U.S.A. and remitted to New Tribes Mission in the Philippines and credited to the account of foreign missionaries concerned. 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 to them prior to their coming to the country, said funds are merely coursed through New Tribes Mission for the account of the foreign missionaries, the said financial support are not, therefore, subject to Philippine income tax. cdta Very truly yours, (SGD.) EUFRACIO D. SANTOS Deputy Commissioner Officer-in-Charge