bir_ruling BIR Ruling No. 367-2022BIR Ruling No. 367-2022

BIR Ruling No. 367-2022

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REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Certificate of Tax Exemption No. CMPEE 3 5 7 - 2 0 2 2

CERTFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

between: This certifies that the Deed of Absolute Sale dated July 7, 2020, entered into by and

Name of Sellers TIN Address Jenny T. Li married to Beini Li

-and-

Name of Homeowners Association (HOA) TI Address

HOMEOWNERS ASSOCIATION, INC. SAN JUAN Brgy. Manambulan, Tugbok District, Davao City 8000

over the parcels of land described below, to wit:

Transfer Certificate of Title Nos. Total Area (sq.m.) Transferred (sq.m.) Area of CMP (st.m} Location

being a Community Mortgage Program (CMP), is not subject to capital gains tax pursuant to Section 32 (b) of Republic Act (RA) No. 7279, as amended by RA No. 10884. The transaction is, however, subject to documentary stamp tax under Section 196 of the National Internal Revenue Code (Tax Code) of 1997, as amended.

Revenue Memorandum Order (RMO) No. 15-2003. 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) concerned in order for the latter to issue the CAR. The CAR shall only be issued after the submission of the requirements provided under It is, however, understood that this Certificate of Tax Exemption (CTE) is never

Sale on behalf of the landowners for the sale of the properties identified and described in TCT Nos. 146-2014072653, 146- 1 Special Power of Attorney dated November 29, 2019, was granted to Susana B. Basuel to execute the Deed of Absolute

2014072654 and 146-2014072655

San Juan HOA, Inc./Sps. Jenny T. Li & Beini Ei Page 2 of 2 CTE No. CMP- 3 6 7 - 2 0 2 2 Date Issued _AUG2 22022

actual occupants of the property transferred under the CMP are qualified beneficiaries and therefore, the seller is entitled to exemption from capital gains tax or income tax imposed under Sections 24 (D)(1) and/or 27 (D)(5) of the Tax Code of i997, as amended. The Bureau of Internal Revenue (BIR) shall conduct verification and post-audit that the

submitted. However, if upon investigation, the BIR ascertains that the facts are different, then this Certificate shall be considered null and void. This CTE is being issued on the basis of the facts and documents as represented and

Issued this day of AUG_2 2_222

Commissioner of Internal Revenue LILIA CATRIS GUILLERMO Uala l.

K-I1-JAC 000802

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