BIR Ruling No. 423-2019

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon Ciry

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CERTIFICATE OF TAXEXEMITION

TO ALL WHOM IT MAY CONCERN:

This certifies that P.A. ALVAREZ PROPERTIES AND DEVELOPMENT CORPORATIONi with Taxpayers Identification Number (TIN) tis exempt

from income tax and creditable withholding tax (CWT) 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 conneotion with

its sale of socialized lots with units for residential and dwelling purposes to qualified beneficiaries in St. Joseph Homes Norzagaray, consisting of 1,624 Jots with units, located at

Regulatorv Board (H Brgv.3go No i. provided that the selling price of said units does not exceed P450.000.002 per der Certificate of Registration No. cana project duly registered with the Housing and Land Uce and Licens

house and iot.

Moreover. the sale by the Company of residential lot valued at P1,919.500.00 and

below, or house and iot and other residential dwellings vained at P3.199.200.00 and beiow, is

exempt from value-added tax (VAT) pursuant to Section 109 (1)(P) of the National Internal Revenue Code of 1997. as amended. Provided. however, that beginning January 01, 2021, the exemption from VAT shall oniy apply to sale of house and lot and other residential dwellings

with selling price of not more than P2.000.000.00.

it is observed, however, that dooumentary stamp tax (DST) is not one of the taxes covered by the tax exemprion 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 National Internal Revenue Code of 1997, as amended, hased on the consideration contracted to be paid for such realties or on their fair market value determined in accordance with Section 6 (E) oi the same Code,whichever is higher.Likewise.lots/units classified as Economic Housing.not

being covered by RA No. 7279. shall be subiect to the payment of appropriate taxes.

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

This Certificate of Tax Exemption 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 JL2 92019

G

CAESAR R.DULAY

K--LMAT Commissioner of Internal Revenue 027260

Sale of lot oniy. regardless of the price. snall be subject to VAT starting January 01. 2021 purs Operating under the name and style of P.A. Properties Per HLURB License to Sell No. ated August 03.2017 iant to RA No.1096