Living Vessel Christian Baptist Church San Pedro, Inc.

May 22, 2009 BIR RULING [NSNP-(S30E-062) 347-09] Sec. 30; S-30-102-2008 dtd. 06/11/2008 Living Vessel Christian Baptist Church San Pedro, Inc. Block 20 Lots 1 & 2 Phase 1, Villa Olympia San Vicente, San Pedro, Laguna Attention: Milo F. Gigare Treasurer Gentlemen : This refers to your letter dated November 27, 2008 requesting for exemption from the payment of income tax, filing of the corresponding income tax return under Section 30 of the Tax Code of 1997, as amended. Documents submitted to this Office disclosed that Living Vessel Christian Baptist Church San Pedro, Inc. is a non-stock, non-profit corporation under Section 30 of the Tax Code of 1997, as amended; that it is duly registered with the Securities and Exchange Commission under SEC Registration No. CN200815578 dated October 03, 2008 with Taxpayer Identification Number (TIN) 007-139-972; and that the main objective for which the corporation was formed is for the administration of its affairs, properties and temporalities. In reply, please be informed that this Office cannot yet issue the requested ruling/certificate of tax exemption. It has to prove by actual operation for at least three (3) years that it is really an organization/association exempt from income tax under Section 30 of the Tax Code of 1997, as amended. It should file the necessary annual information return instead of an income tax return on or before April 15 of each year following the start of its operation as an exempt organization as required under Section 24 of Revenue Regulations No. 2. Based on such information return, we shall conduct the necessary investigation on your activities undertaken during the period. The letter of exemption shall thereafter be issued depending upon the result of our investigation. DaHcAS However, Living Vessel Christian Baptist Church San Pedro, Inc. shall be subject to the corresponding internal revenue taxes imposed under the Tax Code of 1997, as amended, on income derived from any of its properties, real or personal, or 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 instruments and from trust funds and similar arrangements, and royalties derived from sources within the Philippines are subject to 20% final withholding tax; provided, however, that the interest income you derive from a depository bank under the expanded foreign currency deposit system shall be subject to a final withholding tax of 7 1/2% pursuant to Section 27 (D) (1) in relation to Section 57 (A) of the Tax Code of 1997, as amended. Moreover, you are required to file on or before the 15th day of the fourth month following the end of your accounting period a Profit and Loss Statement and Balance Sheet with Annual Information Return under oath, stating your gross income and expenses incurred during the preceding period and a certificate showing that there has not been any change in your By-Laws, Articles of Incorporation, manner of operation and activities as well as sources and disposition of income. It should be understood that Living Vessel Christian Baptist Church San Pedro, Inc. shall be constituted as a withholding agent for the government if it acts as an employer and any of its employees receives compensation income subject to withholding tax, or if it makes payments to individuals or corporations subject to the withholding tax provided for in Section 57 of the Tax Code of 1997, as amended. Finally, its books of accounts and other pertinent records shall be subject to periodic examination by revenue enforcement officers of this Bureau for the purpose of ascertaining whether it has complied the conditions under which it may be granted tax exemption or tax incentives and/or has paid its tax liability, if any, pursuant to Section 235 of the Tax Code of 1997, as amended. This ruling is being issued on the basis of the foregoing facts as presented. However, if upon investigation it will be disclosed that the facts are different, then this ruling shall be considered null and void. CSDcTA Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service