The Logos Covenant, Inc.

September 9, 2009 BIR RULING [NSNP-(S30E-116) 570-09] 27 (D) (1); S-30-012-07 The Logos Covenant, Inc. #15 Champaca St., Roxas Dist. Quezon City Attention: Atty. Pablo M. Inventor, Jr. Legal Counsel and Corporate Secretary Gentlemen : This refers to your letter dated March 17, 2009, requesting for exemption from the payment of income tax and 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 THE LOGOS COVENANT, INC., with Taxpayer's Identification No. 007-259-029-000, is a non-stock, non-profit corporation duly registered with the Securities and Exchange Commission under SEC Registration No. CN200903505 dated March 9, 2009; and that the purposes for which THE LOGOS COVENANT, INC. was incorporated are the following: Primary Purpose To proclaim the word of Jesus Christ and to transform lives through various media communications. Secondary Purposes 1. To publish a magazine in pursuance of the primary purpose; 2. To produce concepts and sponsor movie premieres to raise funds for various Christian ministries; 3. To organize Training and Development, Workshops, Seminars and Symposia geared towards Christian growth and transformation; CSHDTE 4. To participate in outreach ministries and church-related missions consistent with the primary objective; 5. To be given the authority to solicit funds/donations; 6. To be given the authority to negotiate with possible groups and funding agencies; 7. To be given the authority to accept donations whether foreign and local; and 8. To enter into contracts/agreements with the appropriate agencies. 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 can file the necessary annual information return instead of an income tax return on or before the 15th day of the fourth month following the start of its operation as an exempt organization as required under Section 24 of Revenue Regulations No. 2 ( Collector vs. Sinco, G.R. L-9276 dated 23 October 1956). Based on such information return, we shall conduct the necessary investigation on its activities undertaken during the period. The determination letter of exemption shall thereafter be issued depending upon the result of our investigation. However, THE LOGOS COVENANT, 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 it derives 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, it is required to file on or before the 15th day of the fourth month following the end of its accounting period Profit and Loss Statement and Balance Sheet with 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 your By-Laws, Articles of Incorporation, manner of operation and activities as well as sources and disposition of income. It should be understood that THE LOGOS COVENANT, 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 is complying with the conditions under which it may be granted tax exemption or tax incentives and 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. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service