BIR Ruling [UN-094-95]

March 7, 1995 BIR RULING [UN-094-95] Philippine Challenge, Inc. 41 Cordillera Street Mandaluyong City Attention: Mrs . Norma P . Movido Office/Business Manager Gentlemen : This refers to your letter dated December 5, 1994, in effect requesting that financial support intended for your foreign missionaries in the Philippines be exempt from Philippine income tax. cdtech It is represented that Philippine Challenge, Inc. is a non-stock, non-profit religious organization duly registered with the Securities and Exchange Commission (SEC); that it sponsors foreign missionaries in the Philippines to further the proclamation of God's Word and to assist the local churches in its evangelism and church growth program; that it is affiliated with CC International, based at Colorado Springs, U.S.A. and has presently six (6) foreign missionary families serving in the Philippines whose financial support as long as they are in the Philippines is guaranteed by the latter; that the missionaries are required to raise their financial support from Christian friends, churches and relatives prior to overseas assignment, which support is normally channeled through the organization's sending office designated for the ministry of the missionaries; and that said funds are remitted to Philippine Challenge, Inc. for the missionaries work expenses and to the missionaries account for their personal allowances. In reply, please be informed that since the financial support being received by the foreign missionaries are not compensation and/or salary but donations which were given to them prior to their coming in the country; and that the funds are merely coursed through the organization's sending office and then remitted to the Philippine Challenge, Inc. for the account of the foreign missionaries, said financial supports are not, therefore, subject to Philippine income tax. (BIR Ruling No. 21/000-00/54-90 dated April 6, 1990) Very truly yours, ALICIA P. CLEMENO Assistant Commissioner (Legal Service)