BIR Ruling No. 265-2021

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exer Nsu- F5 72071 iption No:

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

Authority (NHA)', is exempt from project-related income taxes and creditable withholding This certifies that CSE Builders, an entity engaged by the National Housing

tax pursuant to Section 20 (d)(1) of Republic Act (RA) No. 7279, as amended by RA No. 10884 (Balanced Housing Development Program Amendments) dated July 17, 2016, on its income received directly in connection with the construction/development of 234 socialized housing units in Dagami Town Ville Housing Project located in Brgy. Sawahon, Dagami, Leyte, intended for the families affected by Typhoon Yolanda under the NHA's Yolanda Permanent Housing Program. Moreover, the delivery of 234 socialized housing units shall be exempt from value-added tax (VAT) pursuant to Section 109 (1)(P) of the National Internal Revenue Code of 1997 (Tax Code), as amended, provided that the selling price thereof does not exceed 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 dwellings.3

However, the purchases of goods/articles by CSE Builders shall 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 CSE Builders must issue VAT Exempt official receipts on its gross receipts from the said socialized housing project.

the Landowner in favor of the NHA over the parcel of land described below. to wit: Moreover, the Affidavit of Self-Adjudication with Deed of Absolute Sale executed by

Date Landowner/Seller Name of of Title No. Certificate Originai (Sq.m.) Area Transferred (Sq. m.) Area Location

September 19, 2019 Felicidad B. Justimbaste 22,476 22,476

G

2 As adjusted in 2011 using the 2010 Consumer Price Index values per Revenue Regulation No. 8-2021 1 Per Contract Agreemernt dated February 7, 2019. 3 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 4 This Certificate of Tax Exemption does not include exemption from estate tax on the transfer of OCT No. registered owner Valentina Lobrigo-Banadora, to her heir. from its

CSE Builders (Dagami Town Ville) Page 2 of 2 Date issued"L.25 202t CTE No._NS# - 2 65-2 0 21

which shall be used for the above-mentioned socialized housing project. is not subject to capital gains tax and documentary stamp tax pursuant to Sections 19 and 20 of Republic Act (RA) No. 7279, and VAT pursuant to Section 109 (1)(P) of the Tax Code. as amended.

It is, however, understood that this Certificate of Tax Exemption (CTE) is never intended, and shall not be construed, as giving authority to concerned Register of Deeds to effect transfer of the land titles in the name of the NHA without the necessary Certificate Authorizing Registration (CAR) issued by this Bureau. In this regard, this CTE. together with the documentary requirements provided under 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 is being issued on the basis of the facts and 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.

Issued this day of_JUL 2 6 2021

K-1-JAC Commissioner of Internal Revenue CAESAR R. DULAY 044193