Exemption of Foreign Missionaries from the Payment of and the Filing of the Corresponding Income Tax Return

November 16, 1990 BIR RULING NO. 209-90 21 054-90 209-90 Gentlemen : This refers to your letter dated October 12, 1990 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 Christian And Missionary Alliance (C&MA) is a non-stock, non-profit corporation organized under the State of New York, U.S.A. and licensed to do business in the Philippines on September 20, 1950; that it has 75 foreign missionaries assigned throughout the country in over 1,500 churches, chapels and mission stations; that these foreign missionaries, raised their financial support prior to their coming to the country, from their friends, relatives and churches abroad who may give it in cash, cheques or pledges; that the funds are normally coursed through the C&MA in the U.S.A. and then remitted to the C&MA Philippine Mission and credited to the account of the foreign missionaries concerned. In reply thereto, I have the honor to inform you 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 C&MA Philippine Missions in the Philippines 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. casia Very truly yours, (SGD.) JOSE U. ONG Commissioner