12 March 2013 Ruling Case No. 138581
A corporation did not qualify as a non-profit organization as it was not organized solely for a purpose other than profit: it was established as a corporation with share capital and without any statement that it was organized for non-profit purposes, and there was no statutory prohibition against it either operating on a for-profit basis or allowing any part of its income to be payable or otherwise available to its shareholders. Furthermore, almost half of its income comes from fees earned for its service and income earned on the sale of its products. These sources of income have allowed it to generate substantial operational surpluses.