Christ is King Mission Fellowship International Incorporated

April 3, 2009 BIR RULING [NSNP-(S30E-043) 250-09] Section 30; BIR Ruling No. S30-080-2007 Christ is King Mission Fellowship International Incorporated Mezzanine Floor, Gran Hotel Bry. 1 & 4, Tacloban City Attention: Mr. Alfonso G. Marzol BOT Vice-President Gentlemen : This refers to your letter dated July 10, 2006 indorsed to this Office by Regional Director Estrella V. Martinez of BIR Revenue Region No. 14 requesting for a certificate of tax exemption in favor of Christ is King Mission Fellowship International Incorporated ("Christ is King" for brevity). As represented, Christ is King is a non-stock, non-profit religious and charitable corporation registered with the Securities and Exchange Commission (SEC) under SEC Registration No. 159870. Its purposes are as follows: "A ADMINISTRATIVE MATTERS: 1. For the administration and management of its temporalities of its affairs, properties and state. 2. To acquire by gift, bequests, device, purchase, exchange or otherwise money and title or interest in real or personal property; to lease, have, use and take possession of and enjoy in fee simple or otherwise all such money, personal or real property necessary for the uses and purpose of the corporation herein set forth, together with the right to sell, lease deed in trust, alienate or dispose of the same at the pleasure of the corporation, and for the uses and purposes for which this corporation is formed; and further to apply the proceeds of sale of any personal of real property of said corporation, including any all income, to the use and purposes of the corporation. 3. To provide and furnish, such building or buildings in partnership with Mindt Ministries International, (the Garmond Mind Memorial Center) and for the said association as may be necessary or convenient, a Christian Worship Center for the preaching and teaching the Gospel of our Lord Jesus Christ, a Bible School, a Preparatory Educational School and Elementary School to educate our children at any location that may be selected or designated by the Officers of the association. 4. To apply all money and all property acquired by it to any and all beneficial purpose and objects which the said Association may select to promote, including the preaching of the Gospel of Jesus Christ, all under the supervision of the officers of said Association. 5. To apply all property acquired, while in its possession, to the purposes, uses and benefits herein expressed, and to prevent its use for any other purpose or in any other manner as herein provided. 6. To contract in the same manner to the same extent as a juridical person; and to borrow money, give promissory notes therefore, and secure the payment thereof by mortgage, deed or trust, bond or other lien on property, real or personal, and otherwise to buy, sell, lease, mortgage or deal in real or personal property in the same manner as juridical person, not engaged in business may do; B SPIRITUAL MATTERS VISION To proclaim the Lordship and Kingship of Christ 1). Evangelism (Matthew 9:37, 38) 2). Discipleship (Proverbs 6:6-11) 3). Church Planting MISSION To minister the needs of the total man. (Spirit, soul and body) 1). Spiritual Needs soul winning (James 5:20) 2). Physical Needs prayer for the sick, health care (James 5:14-16) 3). Material Needs sharing others (Matthew 25:40) 4). Emotional Needs educating people (Col. 3:16) GOAL 1). To be a church that is strong in prayer 2). To be a church that is strong in praise and worship 3). To be a church of mission and giving 4). To train a five fold ministry gifts in church 5). To be a ministering church. C OVER ALL PURPOSE: Establishing the Kingdom of God to the hearts of many people." In reply, please be informed that paragraph 3, Section 28, Article VI of the 1987 Constitution provides, viz. : IcaEDC "(3) Charitable institutions, churches and parsonages or convents appurtenant thereto, non-profit cemeteries, and all lands, buildings, and improvements actually, directly, and exclusively used for religious, charitable, or educational purposes shall be exempt from taxation." The exemption above conferred by the Constitution refers to internal revenue taxes and customs duties, in appropriate cases, imposed by the national government on all revenues and assets of non-stock, non-profit charitable, religious and educational institutions used actually, directly and exclusively for charitable, religious and educational purposes. Moreover, under Section 30 (E) of the Tax Code of 1997, as amended, a nonstock corporation or association organized and operated exclusively for religious, charitable, scientific, athletic, or cultural purposes, or for the rehabilitation of veterans, no part of its net income or asset shall belong to or inure to the benefit of any member, organizer, officer or any specific person is exempt from income taxation. Accordingly, as a non-stock, non-profit religious and charitable organization, Christ is King, therefore, is exempt from tax on all revenues derived in pursuance of its purpose as a religious and charitable organization and used actually, directly and exclusively for religious purposes. However, it is subject to internal revenue taxes on income from other activity the conduct of which is not related to the exercise or performance of its purposes or functions. Moreover it is subject to the corresponding taxes imposed under the Tax Code of 1997, as amended on its income derived from any of its properties, real or personal, regardless of the disposition thereof, which income should be returned for taxation. Likewise, interest income from its currency bank deposits and yield or any other monetary benefits from deposit substitute instruments and from trust funds and similar arrangements received by the organization, 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 28 (A) (7) (a), in relation to Section 57 (A), both of the Tax Code of 1997, as amended. Moreover, as a tax-exempt organization, Christ is King should file an annual information return on or before the 15th day of the 4th month following the end of its taxable year. Under Section 235 of the Tax Code of 1997, as amended, any provision of existing general and special law to the contrary notwithstanding, the books of accounts and other pertinent records of tax-exempt organizations 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. AcHCED 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