A Legal Article in the Philippine Context

I. Overview

Churches and religious organizations in the Philippines commonly hold raffles, benefit draws, fund-raising campaigns, fiesta-related ticket sales, and similar activities to raise money for parish projects, charitable works, construction, feeding programs, medical missions, religious events, and community outreach.

A frequent question is whether church raffle tickets must be covered by a BIR Authority to Print, commonly called ATP. The issue arises because raffle tickets are printed documents used to collect money from the public, but they are not always ordinary sales invoices or official receipts. The answer depends on the nature of the transaction, the tax status of the church or religious organization, whether the ticket represents a donation, a sale, a gaming activity, an admission charge, a fundraising receipt, or evidence of participation in a raffle, and whether other government permits are required.

In Philippine tax practice, churches are not automatically exempt from every tax or every Bureau of Internal Revenue compliance requirement. Religious institutions enjoy constitutional and statutory protection in specific areas, but when they engage in revenue-generating activities, fundraising events, sale of goods, lease of property, or other transactions, they may still have registration, invoicing, withholding, documentary, income tax, VAT or percentage tax, donor’s tax, and reporting considerations.

The core legal question is this:

Does a church need BIR Authority to Print for raffle tickets?

The safest practical answer is:

A church raffle ticket is not always the same as a BIR invoice or official receipt, but if it functions as evidence of payment, sale, donation, admission, or collection, the church should carefully evaluate whether BIR-registered receipts, invoices, or accountable forms are required.

The raffle ticket itself may be governed not only by BIR rules, but also by gaming, solicitation, local government, and fundraising regulations.

II. What Is a BIR Authority to Print?

A BIR Authority to Print is the approval issued by the Bureau of Internal Revenue allowing a taxpayer to print official receipts, sales invoices, and other commercial invoices through an accredited printer.

Historically, taxpayers were required to obtain an ATP before printing manual receipts and invoices. The ATP system ensures that accountable forms used for tax reporting are controlled, serialized, traceable, and linked to the taxpayer’s BIR registration.

The ATP requirement is connected to the BIR’s power to regulate:

Sales invoices;
Official receipts;
Commercial invoices;
Supplementary invoices;
Other accountable forms used in business transactions;
Documents evidencing sales, services, rentals, or collections subject to tax reporting.

A document requiring ATP generally cannot be lawfully printed casually by any printing press without BIR authority. It must follow BIR format, serial numbering, taxpayer information, printer accreditation details, and other required information.

III. What Documents Usually Require BIR ATP?

The documents typically associated with ATP are those used as official tax-accountable documents, such as:

Official receipts, historically used for services, lease, and collection of payment;
Sales invoices, used for sale of goods;
Commercial invoices, depending on the transaction;
Billing statements and collection receipts, if treated as supplementary documents;
Acknowledgment receipts, depending on their use;
Other invoices or receipts required by the BIR to evidence taxable transactions.

Under the modern invoicing framework, the distinction between official receipts and invoices has changed for many transactions, but the principle remains: documents that serve as the taxpayer’s official evidence of taxable sale, service, lease, or collection are regulated by the BIR.

Raffle tickets, however, are not automatically within the ordinary category of sales invoices or official receipts. They may be more like participation tickets, draw stubs, fundraising tickets, or lottery-style entries. Whether ATP is required depends on what the ticket actually represents.

IV. What Is a Church Raffle Ticket?

A church raffle ticket is usually a printed ticket sold or distributed to participants in exchange for a chance to win a prize.

It may contain:

Name of the church, parish, diocese, ministry, foundation, or religious organization;
Purpose of the raffle;
Ticket number;
Price or suggested donation;
Draw date;
Prizes;
Mechanics;
Permit number from the proper authority, if any;
Name of beneficiary project;
Stub for participant and stub for organizer;
Terms and conditions;
Contact details;
Space for name, address, and phone number of buyer.

In practice, churches often treat raffle ticket proceeds as fundraising income or donations. But the legal classification must be examined carefully. Calling the amount a “donation” does not automatically make it a tax-exempt donation if the buyer receives a chance to win a prize in exchange.

V. Key Legal Distinction: Ticket as Raffle Entry Versus Ticket as Official Receipt

The most important distinction is whether the ticket is merely a raffle entry or whether it is being used as the church’s official receipt or invoice for money received.

1. Ticket as raffle entry only

If the ticket merely proves participation in the raffle draw and the church separately issues a BIR-compliant receipt where required, the ticket may not itself be the BIR official receipt or invoice.

2. Ticket as evidence of payment

If the ticket is the only document issued to the payer, shows the amount paid, and is used as proof that the church received money, the BIR may view it as functioning like a receipt or accountable document.

3. Ticket as admission or event ticket

If the raffle ticket also admits the holder to a concert, dinner, parish event, bingo night, benefit show, or fundraising program, it may have characteristics of an admission ticket or event ticket.

4. Ticket as donation acknowledgment

If the ticket says “donation” but gives the donor a chance to win prizes, it may not be a pure donation. It may be a fundraising raffle transaction.

The BIR treatment depends less on the label and more on the substance.

VI. Are Churches Exempt From BIR Requirements?

Churches and religious organizations in the Philippines enjoy tax protections, but these protections are not unlimited.

The Constitution provides tax exemption for charitable institutions, churches, parsonages or convents appurtenant thereto, mosques, non-profit cemeteries, and lands, buildings, and improvements actually, directly, and exclusively used for religious, charitable, or educational purposes. This exemption mainly concerns real property tax.

For income tax, non-stock, non-profit religious, charitable, and similar organizations may be exempt on income received as such, subject to conditions. However, income from properties or activities conducted for profit may be taxable regardless of the disposition of the income.

This means:

A church may be exempt from income tax on certain religious or charitable receipts;
A church may still have BIR registration obligations;
A church may still have withholding tax obligations;
A church may still need receipts or invoices for certain transactions;
A church may still be subject to taxes on unrelated business income;
A church may need permits for raffles and public solicitations;
A church may need proper documentation for donations and fundraising receipts.

A religious purpose does not automatically eliminate all documentation requirements.

VII. Does a Church Raffle Ticket Require BIR ATP?

There is no single answer applicable to all church raffles. The proper answer depends on how the ticket is used.

A. Raffle ticket not used as official receipt

If the raffle ticket is merely a numbered chance ticket and not intended as the official receipt for a taxable sale or service, the ticket may not be the type of BIR receipt or invoice that requires ATP.

However, the church should still document the collection internally and issue appropriate receipts where required.

B. Raffle ticket used as official receipt

If the raffle ticket itself acknowledges payment, bears the amount paid, is issued as the only proof of money received, and functions as the church’s receipt, the safer view is that the church should not print it informally. It should examine whether BIR-registered accountable forms are required or whether official receipts/invoices must be issued separately.

C. Raffle ticket bundled with sale of goods or services

If the church sells meal tickets, concert tickets, event tickets, merchandise, or services and includes a raffle entry, the transaction may be treated as a sale or service transaction. In such case, BIR invoicing requirements become more important.

D. Pure donation with incidental raffle

If the payment is truly a donation and the raffle is incidental, the classification remains risky because the payer receives a chance to win a prize. The more valuable the prizes and the more commercial the raffle, the harder it is to characterize the amount as a pure donation.

E. Raffle conducted by a registered foundation or church corporation

If the raffle is conducted by a foundation, school, hospital, parish corporation, diocese, religious congregation, or separate non-stock corporation, the BIR obligations should be analyzed based on that entity’s registration, tax exemption status, and activities.

VIII. Practical Rule

A practical compliance rule is:

Do not treat a church raffle ticket as a substitute for a BIR official receipt or invoice unless it has been properly authorized, formatted, printed, and recorded in accordance with BIR rules.

If the church wants the ticket to serve only as proof of raffle participation, it should say so clearly and maintain separate accounting records and receipts for collections as appropriate.

IX. BIR Registration of Churches and Religious Organizations

Many churches, parishes, diocesan institutions, religious orders, and church-affiliated foundations are registered with the BIR.

A BIR-registered church or religious organization may have:

Taxpayer Identification Number;
Certificate of Registration;
Registered tax types;
Books of accounts;
Official receipts or invoices;
Withholding tax obligations;
Annual information returns;
Audited financial statements, depending on circumstances;
Donation documentation obligations;
Other compliance obligations.

Before printing or issuing raffle tickets, the organization should review its BIR Certificate of Registration and determine whether the activity is covered by its registered activities and tax types.

X. Raffle Tickets and Official Receipts

A common compliance approach is to separate the two documents:

Raffle ticket — proof of participation in the raffle draw;
Official receipt, invoice, or acknowledgment receipt — proof of money received, if required.

This separation helps avoid confusion. The raffle ticket need not necessarily be printed as a BIR official receipt if it is not used as one. But if payment is received, the organization must still have proper accounting support.

For example:

A parish sells raffle tickets at ₱100 each.
Each ticket has a stub and ticket number.
The parish records ticket issuances and collections in a control sheet.
The parish deposits the proceeds in its bank account.
The parish issues official receipts or donation acknowledgments where required.
The ticket itself states that it is not an official receipt.

This structure is more defensible than using informal tickets as the only collection document without records.

XI. Suggested Wording on Church Raffle Tickets

To avoid confusion, a church raffle ticket may include wording such as:

“This ticket serves only as proof of participation in the raffle draw and is not an official receipt.”

However, this wording alone does not cure non-compliance if the ticket is in fact used as the only proof of payment and no proper accounting or receipt system exists.

If the amount is treated as donation, the ticket may say:

“Donation ticket for fundraising purposes. Please request an official acknowledgment or receipt from the parish office if required.”

Again, the substance of the transaction matters.

XII. Raffle Tickets and Donation Receipts

Churches often use the word “donation” on raffle tickets. This must be handled carefully.

A donation is generally an act of liberality where the donor gives without equivalent consideration. In a raffle, the buyer gives money in exchange for a chance to win a prize. This makes it different from a pure donation.

The ticket price may still support a charitable or religious purpose, but the transaction has a quid pro quo element: the chance to win.

This has several implications:

It may not qualify as a pure donation for tax deduction purposes;
It may not be covered by ordinary donation receipt treatment;
It may require raffle permits;
It may require separate accounting of proceeds and expenses;
It may create tax issues if conducted regularly or commercially.

If a donor gives money without receiving a raffle ticket or chance to win, that is closer to a pure donation. If the person receives raffle entries, the transaction should be analyzed differently.

XIII. Tax Treatment of Raffle Proceeds

The tax treatment of raffle proceeds depends on the nature of the organization and the activity.

1. Religious or charitable purpose

If the raffle is genuinely incidental to religious or charitable fundraising and the proceeds are used for exempt purposes, the church may argue that the funds are part of its exempt or non-profit activity.

2. Regular or commercial activity

If raffles are frequent, large-scale, professionally marketed, or conducted like a business, the BIR may examine whether the activity generates taxable income.

3. Unrelated business income

Even a tax-exempt organization may be taxed on income from activities conducted for profit, especially if the activity is unrelated to its exempt purpose.

4. Net income versus gross receipts

The organization should account for gross ticket collections, prize costs, printing costs, permits, advertising, and net proceeds.

5. Documentation

Proper documentation is crucial to show that proceeds were used for religious, charitable, or civic purposes.

XIV. VAT or Percentage Tax Considerations

Whether raffle ticket sales are subject to VAT or percentage tax depends on the legal characterization of the transaction and the taxpayer’s registration.

A church or religious organization is not automatically VAT-registered merely because it receives donations or conducts fundraising. However, if it sells goods or services in the course of trade or business, VAT or percentage tax issues may arise.

Questions to consider include:

Is the organization VAT-registered?
Is the raffle incidental or regular?
Is the ticket bundled with goods, meals, admission, entertainment, or services?
Is there a separate commercial event?
Are proceeds treated as donations or sales?
Does the organization operate a business activity?

If the raffle ticket is part of a taxable event or sale, BIR invoicing and tax obligations may be triggered.

XV. Withholding Tax Issues

Church raffles may involve payments subject to withholding tax.

Examples include:

Professional fees paid to entertainers, hosts, designers, printers, auditors, or consultants;
Rentals paid for venue, equipment, chairs, sound system, or lights;
Payments to suppliers;
Cash prizes;
Non-cash prizes purchased from suppliers;
Advertising and promotional expenses;
Service fees paid to event organizers.

If the church or organization is a withholding agent, it may need to withhold and remit tax on certain payments.

Even if the raffle proceeds are for religious purposes, supplier and prize payments may still have tax consequences.

XVI. Tax on Raffle Prizes

Raffle winners may have tax implications depending on the nature and amount of the prize.

In the Philippines, winnings and prizes may be subject to final tax or other tax treatment depending on the applicable rules. The organization conducting the raffle may need to determine whether it is required to withhold tax from cash or non-cash prizes.

For example, if a raffle prize is a car, appliance, cash amount, motorcycle, gadget, or house-and-lot, the organizer should determine:

Whether the prize is taxable to the winner;
Whether withholding is required;
Who shoulders the tax;
Whether the prize value is grossed up;
Whether the winner must sign documents;
Whether transfer taxes, registration fees, or other charges apply.

The larger the prize, the more important tax planning becomes.

XVII. Raffle Permits and Government Regulation

Church raffles are not only a BIR issue.

A raffle is a form of chance-based promotion or fundraising. Depending on the nature, scale, and mechanics, permits or approvals may be required from appropriate government agencies or local authorities.

Possible regulatory concerns include:

Local government permits;
Department of Social Welfare and Development public solicitation permits, where applicable;
Gaming or raffle-related permits;
Barangay or mayor’s permit for events;
Police or public order coordination for large events;
Special permits for fund drives;
Reporting requirements after the draw.

A church should not assume that a religious purpose automatically exempts the raffle from all permit requirements.

XVIII. Public Solicitation Issues

If a church or church-affiliated organization solicits money from the public, it should consider public solicitation rules.

Fundraising from members during ordinary religious activities is different from public solicitation campaigns directed to the general public. Selling raffle tickets door-to-door, online, through schools, offices, malls, or public places may raise solicitation permit issues.

The analysis may depend on:

Whether the fundraising is internal to parishioners;
Whether it is open to the general public;
Whether tickets are sold nationwide;
Whether an online platform is used;
Whether proceeds are for charitable beneficiaries;
Whether a third-party organizer is involved.

XIX. Local Government Issues

Local governments may regulate events, business activities, public fundraising, and use of public spaces.

A church raffle connected with a fiesta, concert, bazaar, dinner, or public event may require:

Barangay clearance;
Mayor’s permit;
Special permit for event;
Venue permit;
Public safety coordination;
Fire safety compliance;
Permit for selling goods at booths;
Local amusement or event-related requirements, where applicable.

Local rules vary.

XX. Online Sale of Church Raffle Tickets

Online raffles create additional issues.

If a church sells raffle tickets through Facebook, messaging apps, QR payments, bank transfers, GCash, Maya, online forms, or websites, it should consider:

How ticket numbers are assigned;
How payment is acknowledged;
Whether electronic receipts are issued;
Whether digital raffle tickets are considered official receipts;
Data privacy compliance;
Proof of participant identity;
Mechanics for draw and winner notification;
Audit trail of payments;
BIR documentation;
Permit coverage for online selling or nationwide participation.

A digital ticket may still function as evidence of payment. If so, the organization should ensure that its receipt and accounting treatment is compliant.

XXI. Raffle Ticket Format and Control

Even if the ticket itself is not a BIR ATP-covered official receipt, it should be controlled.

A compliant raffle ticket system should include:

Pre-numbered tickets;
Ticket booklets or pads assigned to sellers;
Master list of issued tickets;
Seller accountability sheet;
Unsold ticket return procedure;
Cash remittance log;
Bank deposit records;
Draw registry;
Winner verification process;
Prize release form;
Post-raffle liquidation report.

This protects the church from fraud, lost collections, duplicate claims, and audit issues.

XXII. Accounting for Church Raffle Proceeds

The church or organization should keep complete records of:

Number of tickets printed;
Number of tickets issued;
Number of tickets sold;
Number of tickets returned unsold;
Total gross collections;
Expenses incurred;
Cost of prizes;
Taxes withheld, if any;
Net proceeds;
Use of net proceeds.

For transparency, especially in church settings, the organization may prepare a liquidation report to the parish council, finance council, donors, or members.

XXIII. Who Should Be the Issuer of the Raffle Tickets?

The identity of the ticket issuer matters.

The issuer may be:

The parish;
The diocese;
A religious congregation;
A church foundation;
A parish pastoral council;
A school or hospital affiliated with the church;
A lay association;
A third-party event organizer.

The entity whose name appears on the ticket should be the same entity responsible for permits, collections, accounting, tax reporting, and prize distribution.

Using one entity’s name while another entity collects the money may create legal and tax problems.

XXIV. Church as Non-Stock, Non-Profit Corporation

Many church-affiliated organizations are organized as non-stock, non-profit corporations. Their tax obligations depend on their registration, purpose, and activities.

A non-stock, non-profit character does not automatically mean all receipts are tax-free or undocumented. It must still maintain books and records, issue proper documentation, and comply with applicable laws.

If the raffle is conducted by a church foundation or non-stock corporation rather than the parish itself, the foundation’s own BIR registration and compliance status should be reviewed.

XXV. Can a Church Print Raffle Tickets at an Ordinary Printing Press?

A church may be able to print ordinary raffle tickets through an ordinary printer if the tickets are not intended to be BIR official receipts, invoices, or accountable tax documents.

However, if the tickets are intended to function as official receipts or invoices, they should not be printed casually. BIR requirements on ATP, accredited printers, serial numbers, and invoice or receipt format may apply.

A conservative approach is:

Print raffle tickets as non-receipt raffle entries;
State that they are not official receipts;
Maintain internal controls;
Use BIR-authorized receipts or invoices separately when necessary.

XXVI. What If the Church Has No BIR ATP?

If the church has no BIR ATP for official receipts or invoices, it should not issue documents that function as official BIR receipts.

The church should first review:

Whether it is BIR-registered;
Whether it has a Certificate of Registration;
Whether it is authorized to print receipts or invoices;
Whether it uses manual, loose-leaf, computerized, or electronic receipts;
Whether the raffle requires issuance of official receipts;
Whether a temporary or special documentation method is available.

It may need to coordinate with its accountant, diocesan finance office, or legal adviser.

XXVII. Does “For Charity” Remove the ATP Requirement?

No. The charitable or religious purpose of the raffle does not automatically remove documentary requirements.

If the document is a regulated receipt or invoice, the purpose of the fundraising does not by itself eliminate BIR formality. Tax exemption and documentation compliance are related but separate concepts.

An exempt organization may still need to prove:

It is exempt;
The activity is within its exempt purpose;
Funds were actually used for the stated purpose;
It complied with applicable documentation requirements.

XXVIII. Are Raffle Tickets “Receipts”?

A raffle ticket is not necessarily a receipt, but it can function as one.

The following factors suggest the ticket functions as a receipt:

It states “received from” or “paid by”;
It states the amount paid;
It is the only document issued for payment;
It is used in accounting as proof of collection;
It is given upon payment;
It bears the name of the collecting organization;
It is used to reconcile cash collections;
It is accepted by participants as proof of payment.

The following factors suggest it is merely a raffle entry:

It states that it is not an official receipt;
It primarily contains raffle mechanics and ticket number;
Separate receipts are issued when needed;
It does not purport to be an invoice or receipt;
It is controlled as a raffle participation document.

XXIX. Should the Ticket Show the Price?

Most raffle tickets show the price because participants need to know the cost. Showing the price does not automatically make the ticket an official receipt. However, it increases the possibility that the ticket will be viewed as evidence of payment.

If the ticket shows the price, the organization should have a clear receipt and accounting policy.

XXX. Suggested Raffle Ticket Information

A church raffle ticket should generally include:

Name of sponsoring church or organization;
Address and contact details;
Purpose of fundraising;
Ticket number;
Ticket price or suggested donation;
Date, time, and venue of draw;
List of prizes;
Permit number, if applicable;
Mechanics;
Deadline for claiming prizes;
Requirement to present winning ticket;
Statement that ticket is not an official receipt, if applicable;
Privacy notice if personal data is collected;
Stub portion for participant details;
Authorized signature or seal, if used.

XXXI. Data Privacy Considerations

Raffle tickets often collect personal information such as name, address, mobile number, email, and signature. Churches and religious organizations should treat this information responsibly.

Basic data privacy practices include:

Collect only necessary information;
Inform participants why the data is collected;
Limit access to ticket stubs;
Secure physical ticket stubs;
Do not publicly disclose unnecessary personal information;
Use personal data only for raffle administration;
Dispose of records securely after the retention period;
Obtain consent for promotional use if needed.

Announcing winners should be done in a way that avoids unnecessary exposure of personal data.

XXXII. Prize Documentation

When a winner claims a prize, the church should require documentation.

XXXIII. Use of Donated Prizes

Many church raffles use donated prizes.

If prizes are donated by parishioners, businesses, or sponsors, the organization should document:

Donor’s name;
Description of prize;
Fair value, if relevant;
Date of donation;
Acceptance by the church;
Whether the donor expects advertising or sponsorship recognition;
Whether a donation receipt is requested;
Whether donor’s tax or deductibility issues arise.

If a business donates prizes in exchange for advertising or sponsorship exposure, the arrangement may not be a pure donation.

XXXIV. Sponsorships and Advertising

Church raffles sometimes include sponsors whose names appear on tickets, posters, tarpaulins, social media posts, or event programs.

Sponsorship payments may have tax consequences different from donations. If a sponsor pays for advertising exposure, the payment may be treated as advertising, sponsorship, or promotional expense rather than a pure donation.

The church should distinguish:

Pure donation with no substantial benefit to donor;
Sponsorship with acknowledgment only;
Advertising arrangement with promotional exposure;
Sale of booth space or event participation rights.

This distinction affects documentation and possible tax treatment.

XXXV. Raffle Tickets Sold by Parish Volunteers

If parish volunteers sell tickets, the church should maintain accountability controls.

Recommended controls include:

Written assignment of ticket booklets;
Record of beginning and ending ticket numbers;
Deadline for remittance;
Official cash count;
Signed remittance form;
Return of unsold tickets;
Prohibition on photocopying tickets;
Report of lost tickets;
Centralized deposit of collections;
Audit by finance committee.

Without controls, the church may face disputes over missing tickets, unpaid collections, duplicate winners, or allegations of irregularity.

XXXVI. Lost, Damaged, or Unsold Tickets

The raffle mechanics should state how lost, damaged, or unsold tickets are handled.

Common rules include:

Lost tickets are not replaceable unless registered and verified;
Unsold tickets are not included in the draw;
Damaged tickets may be accepted if the number is readable and authenticity is verified;
Seller stubs control participation;
The organizer’s decision on ticket validity is final, subject to law.

These rules should be transparent before ticket sales begin.

XXXVII. Raffle Mechanics

A legally safer raffle should have written mechanics, including:

Eligibility to join;
Ticket price;
Sales period;
Draw date and venue;
Method of drawing;
List of prizes;
Deadline for claiming prizes;
Required documents to claim;
Tax treatment of prizes;
Disqualification rules;
Treatment of unclaimed prizes;
Organizer’s contact details;
Permit number, if applicable;
Witnesses during draw;
Posting or announcement of winners.

Written mechanics protect both the church and participants.

XXXVIII. Is a Church Raffle Gambling?

A raffle involves chance, consideration, and prize. In many legal systems, those elements resemble gambling or lottery. However, Philippine law and regulations may allow raffles under specific permits, exceptions, or fundraising rules.

A church should not assume that a raffle is legally harmless merely because it is for a religious cause. The legality of the raffle depends on whether it is properly authorized and conducted under applicable rules.

The organization should avoid:

Unauthorized gambling-like activities;
Repeated commercial raffles without permits;
Misrepresentation of prizes;
Failure to conduct the draw;
Failure to deliver prizes;
Use of proceeds inconsistent with stated purpose.

XXXIX. Internal Church Governance

Churches often have internal rules on fundraising. A parish raffle may require approval from:

Parish priest;
Parish finance council;
Diocese;
Bishop or diocesan chancery;
Religious superior;
School board or foundation board;
Finance office;
Legal office.

Even if civil law permits the raffle, internal church authority may still be required.

XL. Financial Transparency

Because church raffles involve public trust, transparency is important.

Best practices include:

Announcing the purpose of the raffle;
Publishing ticket price and prizes;
Conducting the draw publicly;
Having witnesses present;
Recording the draw;
Preparing liquidation reports;
Reporting gross collections and expenses;
Reporting net proceeds and use of funds;
Safekeeping all receipts, tickets, and stubs;
Auditing the raffle fund.

Transparency helps preserve trust and reduces legal risk.

XLI. Record Retention

The church should retain documents relating to the raffle, including:

Permits;
Approved mechanics;
Printer invoice;
Ticket sample;
Ticket control log;
List of sellers;
Collection reports;
Bank deposit slips;
Expense receipts;
Prize purchase documents;
Prize donation documents;
Winner list;
Prize release forms;
Tax withholding forms, if any;
Final liquidation report.

These records may be needed for internal audit, BIR audit, donor reporting, local government inquiry, or dispute resolution.

XLII. Common Mistakes

Churches and religious organizations commonly make the following mistakes:

Assuming that all church fundraising is automatically tax-free;
Printing tickets that look like receipts without BIR authority;
Failing to obtain proper raffle or solicitation permits;
Calling raffle proceeds “donations” without analyzing the transaction;
Failing to record ticket issuances and collections;
Failing to account for unsold tickets;
Failing to document donated prizes;
Failing to consider tax on prizes;
Using volunteers without accountability controls;
Allowing third parties to collect money without written authority;
Mixing raffle proceeds with personal accounts;
Failing to issue proper receipts or acknowledgments;
Advertising prizes that are not secured;
Conducting online raffles without clear mechanics;
Losing stubs and records after the draw.

XLIII. Conservative Compliance Model

A conservative compliance model for a church raffle is as follows:

Obtain internal church approval.
Determine the legal entity conducting the raffle.
Check BIR registration and receipt/invoice authority.
Determine whether raffle proceeds are donations, fundraising income, sales, or event income.
Obtain required raffle, solicitation, or local permits.
Print raffle tickets as controlled participation tickets, not as official receipts.
Include a statement that the ticket is not an official receipt, if that is the intended treatment.
Use BIR-authorized receipts or proper accounting documents where required.
Control ticket issuance and remittance.
Deposit collections in the organization’s bank account.
Document expenses and prizes.
Determine withholding tax obligations.
Conduct the draw transparently.
Release prizes with documentation.
Prepare a liquidation report.
Retain records.

XLIV. Sample Ticket Disclaimer

A ticket may include a disclaimer such as:

“This ticket is issued solely as proof of participation in the fundraising raffle and is not an official receipt. Proceeds will support the stated parish project. Official acknowledgment may be requested from the parish office where applicable.”

This disclaimer should match the church’s actual process. If the church has no system for official acknowledgment, accounting, or documentation, the disclaimer alone may not be enough.

XLV. Sample Internal Accounting Policy

A church may adopt an internal policy stating:

Raffle tickets are participation documents only;
All tickets must be pre-numbered;
Ticket booklets must be logged before release;
Sellers must remit collections by a fixed date;
Unsold tickets must be returned;
Collections must be deposited intact;
Expenses must be supported by receipts or invoices;
Prize releases must be documented;
Net proceeds must be reported to the finance council;
Records must be retained for audit and legal purposes.

This helps show that the raffle was handled responsibly.

XLVI. When ATP Is Clearly Advisable

ATP or BIR-authorized printing is clearly advisable when the ticket or document is intended to function as:

Official receipt;
Sales invoice;
Commercial invoice;
Admission receipt for a paid event;
Proof of sale of goods or services;
Primary collection document for accounting and tax purposes;
Document to be claimed by payers as expense or donation support.

If the church expects buyers, sponsors, or corporate donors to claim the payment as an expense or donation, the church should not rely on ordinary raffle tickets. Proper official documentation should be issued.

XLVII. When ATP May Not Be Necessary for the Ticket Itself

ATP may not be necessary for the ticket itself when:

The ticket is merely a raffle entry;
It is not used as an official receipt or invoice;
It is not issued as proof of a taxable sale or service;
Separate official receipts or acknowledgments are issued where required;
The ticket clearly identifies itself as a participation ticket;
The organization maintains proper internal records.

Even then, other permits and tax obligations may still apply.

XLVIII. Special Issue: Parish Fiesta Raffles

Parish fiesta raffles are common. They may be treated informally, but legal issues still exist.

A parish fiesta raffle may involve:

Ticket sales by chapel leaders or barangay coordinators;
Donated livestock, appliances, cash, or vehicles;
Public announcements;
Draw during fiesta night;
Local government involvement;
Sponsor advertisements;
Public solicitation.

Because fiesta raffles often involve the public, the parish should be especially careful with permits, ticket control, and financial reporting.

XLIX. Special Issue: School or Parish Organization Raffles

If a Catholic school, parish youth ministry, choir, or church organization conducts the raffle, questions arise as to who is legally responsible.

The organization should clarify:

Is the raffle authorized by the parish, school, or diocese?
Whose name appears on the ticket?
Who receives the money?
Who owns the bank account?
Who buys or receives the prizes?
Who signs the permit applications?
Who reports the proceeds?
Who is responsible if a dispute arises?

Unclear responsibility can create legal and tax exposure.

L. Special Issue: Corporate Buyers of Raffle Tickets

Corporate buyers may ask for official receipts because they want to record the purchase as an expense or donation.

A church should not issue an ordinary raffle ticket as if it were a BIR official receipt. If the corporate buyer needs official documentation, the church should determine whether it can issue:

BIR-authorized receipt or invoice;
Donation acknowledgment, if legally appropriate;
Sponsorship invoice or receipt;
Other proper documentation.

The classification should match the transaction. A raffle ticket purchase is not automatically a deductible donation.

LI. Special Issue: Raffle Ticket as “Donation Ticket”

Many churches label tickets as “Donation Ticket.” This is common, but it can be misleading.

A “donation ticket” with a chance to win prizes is not the same as a pure donation. The buyer pays for a chance to win. The organization should avoid promising tax deductibility unless it has proper legal basis.

A better label may be:

“Fundraising Raffle Ticket”
“Benefit Raffle Ticket”
“Parish Project Raffle Ticket”
“Raffle Entry Ticket”

If the word “donation” is used, the church should still keep proper records and avoid treating all ticket buyers as donors for tax purposes without analysis.

LII. Special Issue: Complimentary Tickets

Sometimes a church distributes complimentary raffle tickets to donors, sponsors, volunteers, or guests.

The organization should document whether complimentary tickets are:

Truly free;
Given in exchange for sponsorship;
Given as a token for donation;
Included in a package;
Counted in the draw.

Complimentary tickets may affect fairness, tax treatment, and raffle mechanics.

LIII. Special Issue: Unsold Tickets Included in Draw

Unsold tickets should generally not be included in the draw unless the mechanics clearly allow it and there is a legitimate reason. Including unsold tickets may raise concerns of manipulation or unfairness.

The church should retrieve and account for all unsold tickets before the draw.

LIV. Special Issue: Printing More Tickets Than Authorized

If a permit authorizes a specific number of tickets, the church should not print or sell beyond that number.

Ticket control should match:

Number of tickets authorized;
Number of tickets printed;
Serial number range;
Number of tickets distributed;
Number of tickets sold;
Number of tickets returned;
Number of tickets included in the draw.

Printing excess tickets without controls may create legal and audit issues.

LV. Special Issue: Major Prizes

Major prizes such as cars, motorcycles, cash, appliances, trips, condominium units, land, or house-and-lot prizes require special care.

The church should determine before the raffle:

Whether the prize has already been acquired or donated;
Who pays registration or transfer fees;
Who pays tax on the prize;
Whether withholding applies;
Whether the winner must pay documentary or transfer costs;
Whether the prize has warranties;
Whether substitution is allowed;
How long the winner has to claim;
What happens if the winner is disqualified or unreachable.

The mechanics should disclose material conditions.

LVI. Risk of Misrepresentation

The church must ensure that raffle advertisements are accurate.

Misrepresentation may occur if:

Prizes are advertised but not available;
The draw is postponed without proper notice;
Ticket proceeds are used for a different purpose;
Permit numbers are fabricated;
Ticket buyers are told the payment is tax-deductible when it is not;
Winners are not properly determined;
The raffle mechanics are changed after ticket sales.

Because churches rely heavily on public trust, misrepresentation risk should be avoided.

LVII. Relationship Between BIR ATP and Raffle Permit

BIR ATP and raffle permit are different.

A raffle permit authorizes the conduct of the raffle or solicitation activity. BIR ATP authorizes printing of official receipts, invoices, or accountable forms.

Obtaining one does not necessarily satisfy the other.

A church may need:

Raffle or solicitation permit;
Local government permit;
BIR registration and receipt/invoice compliance;
Internal church approval;
Accounting and reporting records.

LVIII. Practical Legal Opinion

For Philippine church raffle tickets, the better legal view is:

A raffle ticket is not automatically a BIR official receipt or invoice.
A raffle ticket may be printed without ATP if it is only a controlled raffle entry and not used as an official receipt or invoice.
If the ticket is used as the sole evidence of payment or collection, BIR receipt or invoice issues arise.
Churches are not exempt from all BIR documentation rules merely because they are religious entities.
The organization should separate raffle participation tickets from BIR-authorized receipts or acknowledgments.
Raffle proceeds, prizes, supplier payments, and sponsorships may have tax consequences.
Raffle and solicitation permits may be required independently of BIR ATP.
Proper controls and transparent accounting are essential.

LIX. Compliance Checklist

Before printing church raffle tickets, ask:

Who is the legal organizer?
Is the organizer BIR-registered?
Is the organizer tax-exempt, and for what activities?
What is the purpose of the raffle?
Will tickets be sold only to members or to the public?
Is a raffle or solicitation permit required?
Is a local government permit required?
Will the ticket serve as an official receipt?
Will separate official receipts or acknowledgments be issued?
Does the church have ATP or authority for receipts/invoices?
Will sponsors or corporations require official documentation?
Are prizes donated or purchased?
Are tax withholdings required on prizes or supplier payments?
Are ticket numbers controlled?
Are unsold tickets tracked?
Are online payments documented?
Are personal data of buyers protected?
Are proceeds deposited and liquidated?
Are records retained?
Are final reports prepared?

LX. Conclusion

Church raffle tickets in the Philippines sit at the intersection of tax law, civil regulation, church governance, fundraising practice, and public trust. The BIR Authority to Print requirement does not automatically apply to every raffle ticket merely because it is printed and sold. A raffle ticket may be treated as a participation document rather than a BIR official receipt or invoice, especially when it is clearly marked as such and supported by proper internal accounting.

However, the analysis changes when the ticket functions as the only proof of payment, serves as an admission or sales document, supports a commercial transaction, or is used by buyers as official documentation. In those situations, BIR invoicing and receipt rules, including ATP or equivalent authority, may become relevant.

Churches and religious organizations should not assume that religious or charitable purpose removes all tax and documentation obligations. They should identify the legal organizer, secure necessary raffle or solicitation permits, clarify whether the ticket is a receipt or merely a raffle entry, use BIR-authorized receipts or acknowledgments where required, control ticket issuance, document collections and prizes, consider withholding tax issues, and prepare a transparent liquidation report.

The safest compliance position is to keep the raffle ticket as a controlled raffle-entry instrument, not as a substitute for a BIR-authorized receipt or invoice, unless the ticket has been properly structured and authorized under BIR rules. This approach protects the church, preserves donor and parishioner trust, and reduces the risk of tax, regulatory, and governance problems.