BIR Ruling No. 297-2022

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No:

NNSH - . 2 9 7 - 2 0 2 2

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that A.L. Salazar Construction, Inc. / Ai-Rem Konstruct, Inc. (JV), an entity engaged by the National Housing Authority (NHA), is exempt from project-related income taxes/creditable withholding tax (CWT) pursuant to Section 20 (d) (1) of Republic Act (RA) No. 7279, as amended by RA N. 10884 (Balanced Housing Development Program Ame:. Iments) dated July 17, 2016, on its income received directly in connection with the acquisition/procurement of 348 fu!ly developed lots and completed housing units in Sta. Fe Residences, a socialized housing project of the NHA under the NH.s Yolanda Permanent Ho."ng Program, located at Brgy. Candari, Pandan, Antieue.

Moreover, the delivery of the said 348 fully .developed lots and completed housing units shall be exempt from value-added tax (VAl; :rsuant to Section 109 (1)(P; of the National Internal Revenue Code (Tax Code) of 1997, as amended, provided that the selling price thereof does not exceed P3,199,200.00 per house and lot package; provided further, that beg..ning January 01, 2021, the exemption'from VAT shal! only apply to sale of house and lot and other residential dwellings2 valued at P3,199,200.00.3

However, the purchases of goods/articles by A.L. Salazar Construction, Inc. / Ai Rem Konstruet, Ine. (JV) shall be subject to VAT, ever: if the said purchases are to be used for the above-mentioned 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 A.L. Salazar Construction, Inc. / AI-Rem Konstruct, Inc. (JV) must issue VAT-exempt official receipts on its gross receipts from the said socialized housing project

Furthermore, the Deed of Absoiute Sale made and executed by and between the Landowner/s and the NHA over the parcels of land descrited below, to wit:

202 Date June 02 (Administrator/Beneficial Name of Landowner/s (Herminia C. Fabella) (Teodolfo C. Gabor) Bonifacio Candari Bonifacio Candari Bonifacio Candari (Edgar C. Gabor) User) Tax Declaration {TD) No/s. Area Transferred (s. m.) Location

Total

: Per Meniorandum of the NHA dated February 08, 2022 (Variation Order Mo. 1), the project location was transferred from

2 Sale of lot only, regardless of the price, shall be subject to VAT starting Jary ary 01, 2021 pursuant to RA No. 10963. 3 As adjusted using the 2010 Consumer Price Index values per Revenue Regii ations (RR) No. 8-2021 dated June 11, 2021. + Per TD No. Brgy. Sta. Fe, Pandan, Antique to Brgy. Cay.ari, Pandan, Antique. the registered na:ne of the Administrator/Bene ficial User is Teodulo C. Gabor, Jr.

C

(Sta. Fe Residences) A.L. Satazar Construc. Inc. I Al-Rem Konstruct, Inc. (JV) CTE N Date issi. NSH- JUN 2-0-2022 .297 2ELA

Sections 19 and 20 of RA No. 7279 and to VAT pursuant to Section 109 (1) (P) of the Tax which shall be used for the above' mentioned socialized housing project, are not subject5 to income tax/capital gains tax/expanded withholding tax ard documentary stamp tax pursuant to Code of 1997, as amended.

be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the Certificate Authorizing Registration (CAR). The CAR shall only be issued after submission of Deeds/Assessors Office to effect transfer of the land titie in the name of the NHA without the necessary certificate of authority to register issued by this Bureau. In this regard, this CTE shall intended and shall not be construed as giving authority to the concerned Register of It is, however, understood that this Certificate of Tax Exemption (CTE) is never

the complete requirements provided under Revenue Memcrandum Order (RMO) No. 15-2003.

the Register of Deeds/Assessors Office h : ving jurisdiction over the properties, to the effect that the sa.ne are to be applied or are being applied to a socialized housing project pursuant to RA Upon application for exemption, a lien on the titles of the lands shall be annotated by

No. 7279

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

Issued this day of JUN 2 6 20Z2

1

K- Comnissioner of Internal Revenue CAESAR R. DULAY 0518 8 6 O 2

This CTE does not include exemption frort estate tax which may be due, if any, on the estate of the deceased registered landowner/s.

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