Academy of World Healing Foundation Inc.

May 20, 2009 BIR RULING [NSNP-(S30E-057) 326-09] Section 30; BIR Ruling No. S30-080-2007 Academy of World Healing Foundation Inc. Tagaytay Country Homes 3 Tagaytay City, Cavite Attention: Mr. Keishi Takayama Vice President Gentlemen : This refers to your letter dated May 5, 2009 requesting for tax exemption. Documentary evidence submitted disclosed that Academy of World Healing Foundation Inc. with Taxpayer Identification No. 238-174-664-000 is a non-stock, non-profit social welfare corporation registered with the Department of Social Welfare and Development under Certificate of Registration No. 04A-R-034-09 dated February 4, 2009 and the Securities and Exchange Commission (SEC) under SEC Registration No. CN200507309 dated April 28, 2005. Its primary purposes are as follows: "To be a non-profit holistic wellness center, providing environmental protection and world- and self-healing through harmonious living with each other, nature and the universe. To provide education to invoke spiritual awareness and strives to pursue world peace and healthy lifestyles through grass roots support. To promote natural farming and operate organic gardens and orchards for a healthy and nutritious food supply. To promote and support forestation and to enhance close and healthy drinking water. xxx xxx xxx" In reply, please be informed that under Section 30 (E) of the Tax Code of 1997, as amended, a non-stock 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. DASCIc Accordingly, as a non-stock, non-profit social welfare organization, Academy of World Healing Foundation Inc., therefore, is exempt from tax on all revenues derived in pursuance of its purpose as a social welfare organization and used actually, directly and exclusively for social welfare organization purposes. However, it is subject to internal revenue taxes on income from other activities 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, Academy of World Healing Foundation Inc. 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. 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. CSDcTH Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service