BIR Ruling No. 327-2022

REPUBLIC OF THE PHILIPPINES

DEPARTI.ENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City.

Certificate of Tax Exemption No. CMP3272022

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that the Deed of Absolute Sale dated October 19, 2020, entered into by and between:

KAUNLARAN NG KOMUNIDAD NG CATMON HOMEOWNERS SAMAHAN TUNGO SA ASSOCIATION,INC Name of Seller TIN Brgy. Catmon,Malabon City 219 F.Hernandez Street Address

-and-

Name of Buyer/Member- Beneficiary TIN Address

Marivic V.Santos

over the parcel of land described below, to wit:

Transfer Certificate of Title No. Total Area (sq.m.) Area Transferred (sq.m.) Location

24 24

being a Community Mortgage Program (CMP), is not subject to either the capital gains tax (CGT imposed under Section 27D5 of the National Internal Revenue Code of 1997(Tax Code), as amended, or the creditable withholding tax imposed under Revenue Regulations No. 2-98, as amended, considering thai the said transfer of property is made only as a formality to finally effect the transfer of the said property to its member-beneficiary who has made full

through the Association. In other words, the association is merely transferring the ownership of the property to its member-beneficiary who actually owns the aforedescribed lot. payment of the purchased subdivided lot and actually bought the same from the former owner

property the ownership of which already belongs to the member-beneficiary. donate the said property to said nember-beneficiary, considering that it could not donate of the Tax Code, as amended, since there is no donative intent on the part of the Association to Moreover, the said'transfer is not subject to the donor's tax imposed under Section 98

actuthe owner thereof.Accordinglythe transfer of titie of the bjecit in favor of the thereby excluding from its purview the instant case considering that the &upposed purchaser is realty sold shall be granted, assigned, trsferred, or otherwise conveyed to a purchaser or purchasers or to any other person or persons designated by such purchaser or purchasers. or documents subject to the documentaryamp tax(DST) imposed therein are those where the Furthermore, it is noted that under Section 196 of the Tax Code,as amended, the deeds

A

SAMAHAN TUNGO SA KAUTHARAN NGKOMUNI . AD NG CATMON HOMECWNERS ASSOCIATION.INC.IMARIVIC V.SANTOS Date issued _JUN 2 92022 Coo No. 327-2022

Page 2 of 2

However, the notarial acknowledgment to th . Pzed of Absolute Sale is subject to the DST of above-named beneficiary is not subject to DST under Section 196 oi che Tax Code, as amended

P30.00 pursuant to Section 188 of the same TaxCode.

It is, however, understood that this Certificate of Tax Exemption (CTE is never intended and shall not be construed as giving authority to the concerned Register of Deeds to effect transfer of the land title in the name of the buyer without the necessary Certificate Authorizing Registration (CAR) issued by this Bureau. In this regard, this Certificate shall be presented to the Revenue District Office (RDO) concerred in order for the latter to issue the CAR. The CAR shall only be issued after the submission of the requirements provided under Revenue Memorandum Order (RMO) No. 15-2003.

This CTE is being issued on the basis of the foregoing facts as represented. However if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void.

Issued this day of JUN 2 9 2022

w

Commissioner of Internal Revenue CAESAR R. DULAY

.05 052159 K-1-JA

G