BIR Ruling No. 278-2021

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE

1 BUREAU OE JNTERNAL REVENUE Ouezon ctty

Certificate of Tax Exemption No:

P5+ - 273 -2 82_1

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that RAEMULAN LANDS, INC., with Taxpayer (dentification Number

Section 20 (d) (1) of Republic Act (RA) No. 7279, as amended by RA No. 10884 (Bafanced is exempt from income tax and creditable withholding tax (CWT) pursuant to

Housing Development Program Amendments) dated July 17. 2016, on its income received directly in connection with its sale of socialized house and lot units for residentiaf and dwelling purposes to qualified beneficiaries in Pasinaya Homes Prime North, consisting of 2,350' house and lot units located at Brgy. Timalan, Naic, Cavite, a project duly registered with the

Certificate of Registration No. 2021. provided that the selling price of said house and lot units does not exceed P Department of Human Settiements and Urban Development "(DHSUD) under Provisional and Provisional License to Sell No. Doth dated May 10. 0'per house and lot packages.

Moreover, the sale by the Company of residential lot valued at P1.919,500.00 and below. or house and lot and other residential dwellings valued at P3,199,200.003 and befow, is exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January 01, 2021, the exemption from VAT shall only apply to sale of house and tot and other residential dwellings'valued at P3,199,200.00

Furthermore, the Deeds of Absolute Sale executed by the Landowners in favor of RAEMULAN LANDS, INC. over the parcels of land described below, to wit:

Dec. 03. 2018 Date Ricardo G. Ong married to Julie Ong Name of Landowners Transfer Certificate of Title (TCT) Nos. (sq: m. 2023 29.863 Area (sq. m.) Transferred 2023 29 63 Location

April 30. 2020 Dec. 07. 2018 Sept 24. 2018 Dec 03.2018 Misael Adeiaida P Soliman Marie Tes C. Lee Evelyn K. Chua Myiene T. Lim Tota 39.738 204,735 27.158 30,030 27. 984 29.73 187.614 29.731 39.73 8 27.158 27 984 [ 2, 99

in so far as the 109,ll6.ll" square meters are concerned, which shall be used for the abovementioned socialized housing project are not subject to capital gains tax (CGT) pursuant

The maximum selling price is pegged at ' As adjusted using the 2010 Consumer Price index values pursuant to Revenue Regulation (RR) No. &-2021 dated June 1 1, 2021 ' Per Provisional License to Sell No. 2.350 house and lot units are authorized for sale per house & lot based on DHSUD Provisional License to Sell No

: Sale of lot only, regardless of the price, shall he subject to VAT starting January 01. 2021 pursuant to RA No10963.

" AIready in the name of Raemulan Lands. Inc. under TCT No. " Already in the name of Raemulan Lands, Inc. under TCT No Already in the name of Raemulan Lands. Inc. under TC'T No Already in the name of Raemulan Lands, Inc. under TCT No Already in the name of Raemulan Lands, Inc. under TCT No Already in the name of Raemulan Lands, Inc. under TCT No. and formerly part of TCT No O **

: Per Provisional Certificate of Registration No. igned by the DHSU;D

Page 2 of 3 RAEMULAN LANDS, INC Date issued CTE No. Ps+2 7 3 -_2 0 21

to Section 20 (d) (2) of RA No. 7279, as amended. and to VAT pursuant to Section 109 (1) (P) of the Tax Code' of i997, as amended.

It is observed, however, that documentary stamp tax (DST) is not one of the taxes covered by the tax exemption clause in' Section 20 of RA No. 7279.` Thus, the documents conveying the properties shalibe subject to DST imposed under Section 196 of the Tax Code of i997, as amended. based on the consideration contracted to be paid for such realties or on 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.

The grant of tax exemption herein is subject to the compliance with the provisions of

is liable, however, for all other applicable taxes not enumerated above. applicable BiR rules and regulations and the Terms and Conditions stated hereof. The Company

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_JUL 3 O 2021

K-I-MDT Commissioner of Internal Revenue CAESAR R. DULAY H3t 0 44 29 2q

Page 3 of 3 RAEMULAN LANDS, INC. Date issued Jt{ } i) :21 CTE No.FS H- 2 7 3 - 2 3 21

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

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

exemption shall cover revenues from 2,350 house and lot units with selling price not exceeding attributable to the revenues generated from the project, Pasinaya Homes Prime North consisting of 2,350 house and lot units, located at Brgy. Timalan, Naic, Cavite. Such per house and lot packages.

2. The developer shall submit the sworn statement of the buyer that he is eligible as a socialized housing beneficiary provided under Section 5 (A) of Revenue Regulation (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 socialized housing unit.

3 It is understood that the CAR shall only be issued after it is established upon proper verification

by the Revenue District Officer (RDO) concerned that, considering the rules on valuation of real does not really exceed F property, the actual selling price per sale transaction of the house and lot packages in this case