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

September 11, 1991 BIR RULING NO. 183-91 21 48-91 183-91 Gentlemen : This refers to your letter dated March 27, 1991 requesting for a ruling that the financial support received by the foreign missionaries of Baptist General Conference of America-Philippine Mission is not subject to income tax. It is represented that the Baptist General Conference of America-Philippine Mission, a non-stock, non-profit corporation organized and existing under the State of Illinois, USA, is a tax-exempt organization pursuant to Section 26 of the Tax Code, as amended; that it has foreign missionaries assigned and operating in the Philippines; that these missionaries do not receive compensation from the Philippines; that they derive financial support from funds in the form of cash, cheques and pledges raised from their friends, relatives and churches abroad, prior to their departure for the Philippines; and finally, that these funds are coursed through the mother corporation, BGCA-USA, and then remitted to BGCA-Philippine Mission for the account of the foreign missionaries concerned. In reply, please be informed that since the 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, and that the funds are merely coursed through the BGCA-Philippine Mission for the account of the foreign missionaries, said financial support are not, therefore, subject to Philippine income tax. Very truly yours, (SGD.) JOSE U. ONG Commissioner By: (SGD.) EUFRACIO D. SANTOS Deputy Commissioner Officer-in-Charge