Mission to All the World, Inc.

February 18, 2009 BIR RULING [NSNP-(S30E-010) 108-09] 30 (E);S30-027-2006 Mission to All the World, Inc. Mezzanine Floor Broadway Centrum Aurora Boulevard Quezon City Attention: Ms. Raymunda M. Sayson President Gentlemen : This refers to your letter dated December 5, 2008 requesting for exemption from the payment of income tax and the filing of the corresponding income tax return pursuant to Section 30 of the Tax Code of 1997. Documentary evidence submitted to this Office disclosed that the Mission to All the World, Inc. is a non-stock, non-profit religious corporation duly registered with the Securities and Exchange Commission (SEC) under SEC Registration No. 11207 dated June 26, 1997; that the purpose for which it was formed is to spread the Word of God and the truth of the Holy Bible by whatever means possible, including but not limited to the following: (a) to form a group of Christian true believers belonging to different denominations who adhere strictly to the principles laid down by the Word of God thru the power of the Holy Spirit; (b) to raise up a prayer covering over the world thru the establishment of Prayer Command Centers in every true believer's home for them to stand in the gap for the salvation of their unsaved loved ones, neighbors, and people of the whole world that they may come into the saving knowledge of the Lord Jesus Christ and be concerned with the plight of the poor and the down trodden and many more concerns which God will put in their hearts daily; (c) to proclaim the Word of God in the spirit of true Christian love; (d) to present, produce, create and prepare programs and literature for the dissemination of the "Good News" thru print, radio, television, audio visual tapes, and similar forms of art and media; (e) to preach and teach the Word of God to people from all walks of life, including but not limited to jail inmates and needy families; (f) to acquire and own, through bequest or devise, purchase or donation, and to lease, sell or convey real and personal property as may be necessary to implement its aims and objectives; (g) to collect, raise, borrow and receive all money necessary to meet the financial requirements of the corporation and to do all things and perform such activities that may be directly or indirectly incidental to the attainment of the objectives of the corporation; and that no part of the income which the corporation may obtain as an incident to its operation shall be distributed as dividends to its members, trustees or officers. AECIaD Based on the foregoing, this Office is of the opinion and so holds that the Mission to All the World, Inc. is a corporation organized for religious purposes as contemplated under Section 30 (E) of the Tax Code of 1997. Accordingly, it is exempt from the payment of income tax on income received by it as such organization, and therefore, need not file an income tax return concerning such income. However, it is subject to the corresponding internal revenue taxes imposed under the Tax Code of 1997 on its income derived from any of its properties, real or personal, or any activity conducted for profit regardless of the disposition thereof, which income should be returned for taxation. Likewise, interest income from currency bank deposits and yield or any other monetary benefit from deposit substitute instruments and from trust funds and similar arrangements, and royalties derived from sources within the Philippines are subject to the 20% final withholding tax: provided, however, that interest income derived by it from a depository bank under the expanded foreign currency deposit system shall be subject to 7 1/2% final withholding tax pursuant to Section 27 (D) (1) in relation to Section 57 (A),both of the Tax Code of 1997. Moreover, it is required to file on or before the 15th day of the fourth month following the end of the accounting period a Profit and Loss Statement and Balance Sheet with the Annual Information Return under oath, stating its gross income and expenses incurred during the preceding period and a certificate showing that there has not been any change in its By-laws, Articles of Incorporation, manner of operation and activities as well as sources and disposition of income. It is requested that a copy of this letter of exemption be attached to the annual information return which your corporation will file on or before the 15th day of the fourth month of each year. Under Section 235 of the Tax Code of 1997, any provision of existing general and special law to the contrary notwithstanding, the books of accounts and other pertinent records of tax-exempt organization or grantees of tax incentives shall be subject to examination by the BIR for purposes of ascertaining compliance with the conditions under which they have been granted tax exemptions or tax incentives, and their tax liabilities, if any. It should be understood that the said exempt organization shall be constituted as a withholding agent for the government if it acts as an employer and its employees receive compensation income subject to the withholding tax under Section 79 (A), Chapter XIII, Title II of the Tax Code of 1997, as implemented by Revenue Regulations No. 2-98, or if it makes income payments to individuals or corporations subject to the withholding tax pursuant to Section 57 of the Tax Code of 1997, as implemented by Revenue Regulations No. 2-98, as amended. (BIR Ruling No. DA-S-30-79-98 dated December 29, 1998) ESIcaC This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service