BIR Ruling No. 295-61

August 10, 1961 BIR RULING NO. 295-61 This is in reply to your letters . . . , wherein you requested this Office to issue a ruling on a query stated as follows: cdta "In behalf of my client, the International Child Evangelism Fellowship, Inc., I have the honor to request an official opinion concerning payment of sales tax. This organization is a non-profit, religious corporation organized under the laws of the United States. In 1953 it was licensed by the Bureau of Commerce here in Manila to do business in the Philippines. However, it is not really engaged in "business" as this term is ordinarily understood. The group's main activity here is the evangelization of children. Their missionaries teach children the Word of God and train Christians to teach the Bible to them. cdt Incidentally, they have pamphlets, religious literature and the like, intended primarily for teachers. These are sent to the mission's missionaries here from the States. They sell these publications and some Tagalog translations which are produced here in the Philippines, to the teachers and to the children themselves. Unlike business firms, however, they sell at cost or below cost and, therefore, make no profit at all. Besides, they do not have a store within the plain view of the public. What they have are merely cabinets where they place all the religious literature and these are right in the living room of the house that they occupy. They are renting the second floor. In view of all the foregoing, I wish to request your official opinion as to whether or not my client is liable for payment of sales tax which ordinary business firms pay." As represented, your client, the International Child Evangelism Fellowship, Inc., is not subject to any internal revenue taxes. As such, it is not required to keep books of accounts or their equivalents. cdti