Rangers for Christ Mission Group, Inc.

December 17, 2009 BIR RULING [NSNP-(S30E-155) 796-09] NSNP; RMC 14-2001 Rangers for Christ Mission Group, Inc. Minanga, Camalaniugan, Cagayan Attention: Ms. Anabel V. Ragsac President Mesdames : This refers to your letter requesting for a certificate of tax exemption in favor of the Rangers for Christ Mission Group, Inc. ("RCMGI"), a nonstock, nonprofit religious organization exclusively devoted to religious work, duly registered with the Securities and Exchange Commission (SEC) under SEC Registration No. CN200607040 dated May 8, 2006, with Taxpayer Identification No. 006-300-007. RCMGI conducts evangelism, teaching and discipleship through friendly evangelical crusade and medical missions. It establishes churches, charitable children ministries, and pictorial training centers in order to prepare God's people for the task of shepherding the congregation of the church. The funds of RCMGI are coming from donations and contributions of its members. No part of its income inures to the personal gain of any individual. In reply thereto, please be informed that Section 30 (E) of the Tax Code of 1997, as amended, exempts from income taxation 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. Accordingly, and since RCMGI is a non-stock, non-profit religious organization, it is therefore exempt from tax on all revenues derived in pursuance of its purpose as such. 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. DcTaEH Likewise, interest income from its currency bank deposits and yield or any other monetary benefit from deposit substitute instruments and from trust funds and similar arrangements received by the organization, and royalties, derived from sources within the Philippines, if any, shall be 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, RCMGI is required to file on or before the 15th day of the fourth month of the preceding accounting period a Profit and Loss Statement and Balance Sheet with Annual Information Return under oath, stating its gross income and expenses incurred during the year 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. Further, under Section 235 of the Tax Code, 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, i.e., RCMGI, shall be subject to periodic 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 RCMGI shall be constituted as withholding agent of the government if it acts as an employer and any of its employee receives compensation income subject to withholding tax, or if it makes income payments to individuals or corporations subject to the expanded withholding tax provided for in Section 57 (B) of the Tax Code of 1997. (BIR Ruling No. S-30-023-99 dated March 15, 1999) 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 as null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service