BIR Ruling No. 290-2022

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No:

*NSH - : 2 9 0 - 2 0 2 2

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that Shalom Construction, Inc., an entity engaged by the National Housing Authority (NHA),: is exempt from project-related income taxes/creditable withholding tax (CWT) pursuant to Section 20 (d)(1) of Republic Aci (RA) No. 7279, as amenaed by RA No. 10884 (Balanced Housing Developmeat Program Amendments) dated July 17, 2016, on its income received directly in connection with the construction/procurement of "239'fully'developed lots and completed housing units in Holy Child Residences, a socialized housing project of the NHA under the I - IA's Yolanda Permanent Housing Program located at the Municipality of Makato, Aklan.

Moreover, the delivery of the said 239 fully developed lots and completed housing units shall be exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code (Tax Code) of 1997, as amended, provided that the selling price thereof does not exceed P3,199,200.00 per house and lot package;= provided further, that beginning January 01, 2021, the exemption'froin VAT shall only apply to sale of house and lot and other residential dwellings' with selling price of not more than P3, : 99,200.00.2

However, the purchases of goods/articles by Shalom Construction, Inc. shall be subject to VAT, even if the said purthases are to be used for the' socialized housing project. since V AT is an indirect tax which can be passed on by the seller of the goods/services.It shali be understood that Shalom Construetion,Inc. must issue VAT-exempt official receipts on its gross receipts from the said socialized housing project.

Furthermore, the Deed of Absolute Sale executed by the Landowner/s in favor of the NHA over the parcel of land described below; to wit:

Date Name of Landowner/s Tax Declaration No. Area Transferred (Sq. m.) Location

May 24 2022 Benjamen Minor Terencio i!

which chall be used for the above meationed socialized housing project, is hot subject to income tax/capital gains tax/expanded withhoiding tax and documentury stamp tax pursuant to Sections 19 and 20 of RA No. 7279 and to VAT pursuant to Sectiof i09 (1) (P) 'of the Tax Code of 1997, as amended.

intended and shall not be construed as giving authority to the concerned Register of It is, however, understood that this Certificate of Tax Exemption (CTE) is ne'ver

Deeds/Assessors Office to effect transfer of the land title in the name of the NHA without the necessary certificate of authority to register issued by this Bureau. In this regard, this CTE shall be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the

I Sale of lot only, regardless of the price, shall be.subject to VAT starting Januer: 01, 2021 pursuant to RA No. 10963. 2 As adjusted using the 2010 Consumer Price Incex values per Revenue Regulati-ons (RR) No. 8-2021 dated June 11, 2021.

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Shalom Construction, Inc. (Holy Child Residences) CTE No. Date issued: NSH. 290 20 22 JUN 9 2022

Certificate Authorizing Registration (CAR). The CAR shall only be issued after submission of the complete requirements provided under Revenue Memorandum Order (RMO) No.15-2003.

Upon application for exemption, a lien on the title of the land shall be annotated by the Register of Deeds/Assessors Office having jurisdiction over the property, to the effect that the same is to be applied or is being applied to a socialized housing project pursuant to RA No. 7279.

This CTE is being issued on the hasis of the facts and documents as represented and submitted. However, if upon investigatio.. the BIR ascertains that the facts are different, then this Certificate shall be considered null and void.

Issued this day of JUN 0 9 2022

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K Commissioner of Internal Revenue CAESAR R. DULAY d05 17 82

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