BIR Ruling No. 516-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No:

PSH-0516-202u

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

creditable withholding tax (CWT) pursuant to Section-20 (d) (1) of Republic Act (RA) No. dated July 17, 2016, on its income received directly in connection with its sale of socialized house and lot units for residential and dwelling purposes to qualified beneficiaries in Primerarosa Residences Phase 2, consisting of 827 house and lot units, located at Brgy. Sta. Teresita, Sto. Tomas, Batangas, a project duly registered with the Housing and Land Use Regulatory Board (HLURB) under Certificate of Registration No. house and lot. Taxpayers Identification Number (TIN) 7279, as amended by RA No. 10884 (Balanced Housing Development Program Amendments) No. This certifies that SUMMERHILLS HOME DEVELOPMENT CORP. with , provided that the selling price of said units does not exceed P580,000.00' per is exempt from income tax and and License to Sell

below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, 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 with selling price of not more than P2,000,000.00. exemption from VAT shall oniy apply to sale of house and lot and other residential dwellings- Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

SUMMERHILLS HOME DEVELOPMENT CORP.over a parcel of land described below to wit: Furthermore, the Deed of Absolute Sale executed by the Landowners in favor of

Date 1. Gabriel B. Rosales, married Name of Landowners Certificate of Title (TCT) Transfer No. (sq. m.) Area Transferred (sq. m.) Location

to Jeannie Yoder: December 1,2015 2. Gilbert B. Rosales, married 3. Teresita R. Pastor, married to Amelia Buencamino: and to Teodoro Pastor. Sto. Tomas, Batangas

capital gains tax (CGT) and VAT pursuant to Section 20 (d) (2) of RA No. 7279, as amended. and Section 109 (1) (P) of the National Internal Revenue Code of 1997, as amended. in so far as the area corresponding to the 827 house and lot units is concerned, is not subject to

being covered by RA No. 7279, shall be subject to the payment of appropriate taxes. covered by the tax exemption 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, based on the consideration contracted to be paid the same Code, whichever is higher. Likewise, lots/units classified as Economic Housing, not for such realties or on their fair market value determined in accordance with Section 6 (E) of It is observed, however, that documentary stamp tax (DST) is not one of the taxes

2Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. Per HLURB License to Sell No Sdated July 23,2019. 2

SUMMERHILLS HOME DEVELOPMENT CORP (Primerarosa Residences Phase 2) Date issued:SFP202 CTE No.: PSH-0516-Z02

applicable BiR rules and regulations and the Terms and Conditions stated in Annex Ahereof. The Company is liable, however, for other applicable taxes not discussed above. The grant of tax exemption herein is subject to the compliance with the provisions of

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. This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this day of SEP 1 5 2920

A,a CAESAR R.DULAY

K-I-LMAT Commissioner of Internal Revenue 036698

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SUMMERHILLS HOME DEVELOPMENT CORP (Primerarosa Residences Phase 2) CTE No.: PSH-0516-2020

Date issued: SEP 15 2020

ANNEX "A"

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the 827 socialized house and lot units in Primerarosa Residences Phase 2, located at Brgy. Sta. Teresita, Sto. Tomas, Batangas.

2. The developer shall submit the sworn statement of the buyer that he is eligible as a socialized

housing beneficiary under Section 5 (A) of Revenue Regulations (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 title 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 property, the actual selling price per sale transaction of the socialized house and lot packages in this case does not really exceed P580,000.00.

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