BIR Ruling [UN-175-95]

April 28, 1995 BIR RULING [UN-175-95] Society of Saint Paul 7708 St. Paul Road San Antonio Village Makati Attention: Fr . Reynaldo F . Reyes General Manager Gentlemen : This refers to your letter dated January 3, 1995 stating that the Society of Saint Paul Inc. formerly Pious Society of Saint Paul is registered with the Securities and Exchange Commission dated September 27, 1963; that it is a religious congregation of priests and brothers serving the faithful thru the media of social communications; and that in the furtherance of this mission the society prints, publishes, sells and even imports books for religious growth. Based on the foregoing representations, you now request a certificate of tax exemption from VAT under Section 103(f) of the Tax Code, as amended. In reply, please be informed that pursuant to Section 103(f) of the Tax Code, as amended by E.O. 273, printing, publication, importation or sale of books among others are exempt from value added tax. Thus, it has been ruled by this Office (citing the case of American Bible Society vs. City of Manila, G.R. No. L-9637, April 30, 1957) that a corporation, the main purpose of which, is the dissemination of catholic doctrine thru the publication and distribution of religious books, pamphlets and other printed matters is not subject to any internal revenue tax on business on its sale of exclusively religious books and publications. However, income derived from any of its activities conducted for profit, regardless of the disposition made of such income, shall be subject to tax imposed under the Tax Code, as amended. (BIR Ruling dated September 23, 1957) Very truly yours, ALICIA P. CLEMENO Assistant Commissioner (Legal Service)