50% Exemption Granted to Philippine Cycling Association, Inc.

May 6, 1958 BIR RULING NO. 254-58 Mr. Geruncio Lacuesta Executive Secretary Philippine Cycling Association, Inc. R-266 Republic Supermarket Bldg. Rizal Avenue, Manila S i r : Reference is made to your letter, dated February 10, 1958, requesting a ruling as to whether or not the Philippine Cycling Association, Inc. is a duly registered charitable institution for purposes of exemption from the payment of the amusement tax in accordance with the provisions of Section 261 of the Tax Code. In reply thereto, I have the honor to inform that, while it is among the purposes of that Association "to donate money, goods, or other property to government entities, charitable institutions and worth causes . . ." this fact by itself will not make the Association a charitable association if actually it is not duly registered and operated as such. After a careful perusal of your Articles of Incorporation, this Office believes, as it hereby holds, that the Association is not a charitable but an athletic association. It may be stated in this connection that charitable institutions or associations are not entitled to full but only 50% exemption. LibLex Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue