BIR Ruling No. 594-2020

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: DCH-594-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that WOODENDRAGON INC.with Taxpayer's Identification Number (TIN)

, is exempt from income tax and creditable withholding tax (CWT) pursuant to Section 20(&)(1) of Republic Act (R.A.) No. 7279, as amended by R.A. No. 10884 (Balanced Housing

Development Program Amendments) dated July 17, 2016, on its income received directly in connection

with its sale of socialized housing units for residential and dwelling purposes to qualified beneficiaries in Nueva Esperanza Pueblo, consisting of 163 lots/units, located at Brgy. Molino, Naic Cavite, a

project duly registered with the Housing and Land Use Regulatory Board (HLURB) under Certificate

of Registration No. and License to Sell No. provided that the ceiling price per house

and lot package does not exceed P580,000.001.

Moreover, the sale by the Company of residential lots valued at P1,919,500.00 and below, or

house and lot and other residential dwellings valued at P3,199,200.00 and below, is VAT-exempt

under Section 109(1)(P) of the 1997 Tax Code, as amended. Provided, however, that beginning

January 1, 2021, the VAT exemption shall only apply to sale of house and lot and other residential

dwellings2 with selling price of not more than Two Million Pesos (P2,000,000.00).

Nonetheless, it is observed that documentary stamp tax (DST) is not one of the taxes covered

by the tax exemption clause in Section 20 of RA No. 7279. Such being the case, the owner/project

developer/seller shall be liable to pay the documentary stamp tax on the documents conveying the

properties imposed under Section 196 of the Tax Code of 1997, 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 R.A. 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 applicable

BIR rules and regulations and the Terms and Conditions stated at the back hereof. The Company is

liable, however, for all other applicable taxes not discussed above.

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 OCT 1 5 2020 A ae3a1a

CAESAR R. DULAY

K-1 Commissioner of Internal Revenue 037040

2 Sale of lot ony, regardless of the price, shall be subject to VAT starting January 1, 2021 pursuant to RA No. 10963. 1 The maximum selling price is pegged at I per house and lot based on HLURB License to Sell No.

WOODENDRAGON INC./Nueva Esperanza Pueblo Page2of2 CTENo.PGH-0534-2020 Date issued _CT 1 5 2020

TERMS AND CONDITIONS

OF THE CERTIFICATE OF TAX EXEMPTION

1. The exemption from income and.creditable withholding taxes covers only income directly attributable to the revenues generated from the. 163 socialized housing units in Nueva Esperanza Pueblo, located at Brgy. Molino, Naic Cavite.

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 BIR

title of the socialized housing unit. during the processing of the Certificate Authorizing Registration (CAR) for the transfer of the

3. It is understood that the Certificate Authorizing Registration (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.

4 List of Non-saleable/Open Space lots per HLURB License to Sell No. granted by the

HLURB,.to wit:

Community Facility - Block 6, Lot 23