Whether the Proceeds that Would be Derived from "Big Bang Sa Alabang" Carnival Activity are Exempt from Tax

August 13, 1992 BIR RULING NO. 221-92 25 (g) 127-90 221-92 The Philippine National Red Cross National Headquarters Bonifacio Drive, Port Area Manila Attention: Ms . Gloria B . Senador Secretary General Gentlemen : This refers to your letter dated March 16, 1992 stating that Her Excellency President C. Aquino has authorized the Philippine National Red Cross (PNRC) under Presidential Proclamation No. 12, to conduct its 1992 Fund Campaign and Membership Drive; and that one of its fund raising events is sponsoring the "Big Bang Sa Alabang" carnival activity from November 21, 1992 to January 3, 1993 on a vacant lot in front of Ayala Alabang Village, Muntinlupa, Metro Manila. In this connection, information is requested as to whether the proceeds that would be derived from said carnival activity are exempt from tax. In reply, please be informed that pursuant to Section 4, paragraph b of P.D. No. 1264 the PNRC shall be "exempt from the payment of all duties, taxes, fees and other charges of all kinds . . . in its benefits and fund raising drives all provisions of law to the contrary notwithstanding." In view thereof, this Office is of the opinion as it hereby holds that the proceeds to be derived from the "Big Bang sa Alabang" carnival sponsored by the PNRC, as part of its annual fund raising campaign authorized under Presidential Proclamation No. 12, are not subject to income and amusement taxes. Very truly yours, JOSE U. ONG Commissioner of Internal Revenue