BIR Ruling No. 419-2021

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: PSH-419 -20

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that Rosand Builders Corporation, an entity engaged by the Quezon City Government', is exempt from project-related income taxes and creditable withholding tax pursuant to Section 20 (d)(1) of Republic Act (RA) No. 7279, as amended by RA No. 10884

dwellings3 with selling price of not more than P3, 199,200.00. condominium units three-storey walk-up in, Bistekville-28 (Phase l) located at Brgy. Quezon City. Moreover, the delivery of 102 socialized housing units shall be exempt from value-added tax (VAT) pursuant to Section 109 (1)(P) of the National Internal Revenue Code P3,199,200.002 per house and lot package; provided further, that beginning January 01, 2021. the exemption from VAT shall only apply to sale of house and lot and other residential (Balanced Housing Development Program Amendments) dated July 17, 2016, on its income received directly in connection with the Hand development and construction of :102 Nagkaisang Nayon, Quezon City, intended for the qualified informal settler families (ISFs) in (Tax Code) of 1997, as amended, provided that the selling price thereof does not exceed

However, the purchases of goods/articles by Rosand Builders Corporation, shail be subject to VAT, even if the said purchases are to be used for the socialized housing project, since VAT is an indirect tax which can be passed on by the seller of the goods/services. It shall be understood that Rosand Builders Corporation must issue VAT exempt official receipts on its gross receipts from the said socialized housing project.

Moreover, the Deed of Absolute Sale executed by the Landowners in favor of the City Governiment of Quezon City over the parcel of land described below, to wit:

Date of Deed of Absolute Sale February 17. 2017 Mary Dorothea Tan Sps. Ernesto Chan and Sps. Rogelio Chan and Angelita Chan Luisa Lim Chan Sps. Amado Chan and Chan Edna Uy Chan Landowners Name of ISellerst Certificate of Transfer Title No. {Sq.m.) 7,809 Area Transferred (Sq. m.) 7,809 Area Location

landowners for the sale of the property identified and described in TCT No. 2 As adjusted using the 2010 Consumer Price Index values per Revenue Regulation No. 8-2021. 3 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 4 Special Powers of Attorney were executed in favor of Lourdes Chan to execute the Deed of Absolute Sale on behalf of the Per ent dated August 14, 2018.

Page 2 of 2 Rosand Builders Corporation Date issued NOV 1 8 2U2i CTE No. PSH - 4 1 9 - 2 0 2 t.

Lourdes Chan Rosa Chan

which shall be used by the City Government of Quezon City for the development of a socialized housing project for the benefit of Quezon City Informal Settlers Families (ISFs), is not subject to capital gains tax pursuant to Section 20 (d)(2) of RA No. 7279 and to VAT pursuant to Section 109 (1)(P) of the Tax Code of 1997, as amended. The transaction is, however, subject to documentary stamp tax under Section 196 of the Tax Code of 1997, as amended, based on the actual consideration of the property transferred considering that one of the parties is the Government.

intended, and shall not be construed, as giving,authority to concerned Register of Deeds (RD) to effect transfer of the fand title in the name of the City Government of Quezon City without It is, however, understood that this Certificate of Tax Exemption (CTE) is never

the necessary Certificate Authorizing Registratisn (CAR) issued by this Bureau. In this regard)

Order (RMO) No. 15-2003, shall be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the CAR. this CTE, together with the documentary requirements provided under Revenue Memorandum

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

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

Issued this day of NOV 9 8 2021

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Commissioner of Internal Revenue CAESAR R. DULAY 046985 K-1-JAC