BIR Ruling No. 642-2020

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: NSH-0642-202C

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that BSP & COMPANY INC. (TIN: ). an entity

engaged by the National Housing Authority (NHA), is exempt from project-related income taxes, creditable withholding tax and value added tax (VAT), pursuant to Section 20 (d)(1) and

(3) of Republic Act 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 socialized housing units under the NHA's Yolanda Permanent

Housing Program, to wit:

No. of

December 7, Notice of Date of Award 2017 Agreement Contract April 30. Date of 2018 Contract Price (Php) Mercedes Project Name Villa 3 Bantayan, Bantayan Site 4, Brgy. Sillon, Island, Cebu Location Housing Units subject of tax exemption Socialized

However, the purchases of goods/articles by BSP & COMPANY 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 BSP & COMPANY'must issue VAT Exempt official receipts on its gross

receipts from the said socialized housing project.

Moreover, the Deeds of Absolute Sale/ Unilateral Sale Executed by the Landowners in

favor of the NHA over the parcel of land described below, to wit:

Deeds of May 22, May 27, Date of 20192 20193 Sale Heirs of Restituto Ysulan Heirs of Arsenio Escaran Heirs of Salvacion Escaran Eliseo B.Nicor Domingo G.Escanillan Meliton Alolod Rolito Sisduyro Landowners/Sellers .Name of Certificate of Original Title No. (Sq.m.) 2,315 14,446 2,241 6,677 4.735 2,951 6,775 Area Transferred (Sq. m.) 14,446 6,775 4,735 2,241 2,315 6,677 2,951 Area Location Bantayan, Sillon, Cebu

Represented by Atty-in-Fact, Isidra Ysulan-Desabille, by virue of Special Power of Attorney dated April 24,2018.

Date acknowledged by National Housing Authority (NHA) 2 Date acknowledged by Isidra Ysulan-Desabille.

Page 2 of 2 BSP & COMPANY INC. - Villa Mercedes'3 CTE-No. NGH-0 6 2 - 2 0 2 Q Date issued NOV 2 42020

which shall be used for the above-mentioned socialized housing project, is niot subject to capital

gains tax and documentary stamp tax pursuant to Sections 19 and 20 of Republic Act (RA) No.

7279.

It is, however, understood that this 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 buyer without the necessary Certificate Authorizing Registration (CAR) 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 CAR.

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 ofNOV 2 4 2O

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Commissioner of Internal Revenue CAESARR.DULAY

K1-JAC 038010