BIR Ruling No. 374-2021

REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No:

PSH - 37E 7024

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

Park III consisting of 2871 house and lot units and 492 lots, located at Brgy. San Agustin, (Batch 1), Provisional License to Sell No. CORP., with Taxpayer Identification Number dated July 17, 2016, on its income received directly in connection with its sale of socialized house and lot units for residential and dwelling purposes to qualified beneficiaries in Highiand and creditable withholding tax (CWT) pursuant to Section 20 (d) (1) of Republic Act (RA)'No. Board(HLURB)3 under Certificate of Reristration No. 7279, as amended by RA No. 10884 (Balanced Housing Development Program Amendments) Tiaong, This certifies that SR. STO.NINO DE CEBU RESOIRCES & DEVELOPMENT Quezon, a project duly registered with the Honciny and Land "Use Regulatorx? (Batch II) License to Sell No. is exempt from income tax

residential dwellingst with selling price of not more than P3, 199,200.005. below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal 01, 2021, the exemption from VAT shall only apply to sale of house and Iot and other Moreover, the sale by the Company of residential lot valued at P1,919'500:00 jand

their fair market value determined in accordance with Section 6 (E) of the 'same Code, whichever is higher. Likewise, lots/units classified as Economic Housing, not being covered by RA No. 7279, shall be subject to the payment of appropriate taxes. of 1997, as amended, based on the consideration contracted to be paid for such realties or on covered by the tax exemption clause in Section 20 of RA No. 7279. Thus, the documents conveying the properties shall be subject to DST imposed under Section 196 of the Tax Code It is observed, however, that documentary stamp tax (DST) is not one.of the taxes

appiicable BIR rules and regulations and the Terms and Conditions stated at the'back hereof The Company is liable, however, for other applicable taxes not discussed above. The grant of tax exemption herein is subject to the compliance with the provisions of

documents as represented and submitted. However, if upon investigation, the BIR ascertains that the facts are different, then this Certificate shall be considered null and void. This Certificate of Tax Exemption is being issued on the basis .of the facts 'and

Issued this day of 0CT 0 6 2021

a

K-MDT Commissioner of Internal Revenue CAESAR R. DULAY 046104

3Now: Department of Human Settlements and Urban Development (DHSUD) 2 Per Provisional License to Sell Ivo. I Out of the 287 hovco and lot units, 192 house and lot units shall not be sold for more than P450,000.00 per uinit per License to Sell No. "Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 202 1 pursuarit to RA No. 10963. SAs adjusted using the Consumer Price Index values pursuant to RR N0. 8-2021 dated June 11, 2021. Provisional License to Selt No. while the 95 house and loi units shall not be sold for more than P480.000:00 per unit per I the 49 lots shall not be sold for more than P232,000.00'per lot.

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption from income and creditable withholding taxes covers only income directly

attributable to the revenues generated from the 287 sociatized house and lot units and 49 lots for residential and dwelling purposes in Highland Park III, located at Brgy. San Agustin, Tiaong. Quezon.

The developer shall submit the sworn staternent of the buyer that he is eligible as a socialized housing beneficiary under Section 5 (A) of Revenue Regulations (RR) No. 11-97 to the Bureau of Internal Revenue (BIR) during the processing of the Certificate Authorizing Registration (CAR) for the transfer of the title of the socialized housing unit.

3 It is understood that the CAR shall only be issued after it is estabiished upon proper verification by the Revenue District Officer (RDO) concerned that, considering the rules on valuation of real

property, the actual selling price per sale transaction of the socialized house and lot packages in this case does not really exceed P450,000.00 on the 192 house and lot units, P480,000.00 on the 95 house and lot units, and P233,000.00 on the 49 lots.