BIR Ruling No. 441-2021

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: NSH-4 41-2021

CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN:

the exemption from VAT shall only apply to sale of house and"lot and other residentiai dwellings' with selling price of not more than P3,199,200.00.2 (Tax Code) of (997, as amended, provided that the selling price thereof does not exceed P3,199,200.00 per house and lot package; provided further, that beginning January 01, 2021. of "Republic Act (RA) No. 7279,as amended_by RA No. I0884 (Balanced Housing Yolanda Permanent Housing Program through fund transfer to the Municipality of Santa Fe. Cebu, located at Brgys. Ocoy and Balidbid, Santa Fe, Cebu. value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code Joint Venture, 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) Municipality of Sta. Fe Sites 1 & 2, a socialized housing project of the NHA under the NHA's Development Program Amendments) dated July 17, 2016, on its income received directly in connection with the land deveiopment and construction of 1,305 socialized housing units in Moreover, the delivery of the said 1,305 socialized housing units shall be exempt from This certifies that WTG Construction & Development Corp. / RDY Constructor

are to be used for the socialized housing project, since'VAT is an indirect tax which can be receipts on its gross receipts from the said socialized housing project. & Development Corp. / RDY'Constructor -- Joint Venture must issue VAT-exempt official passed on by the seller of the goods/services."It shall be understood that WTG.Construction Government of Santa Fe, Cebu, over the parcels of land described below, to wit: Corp. / RDY Constructor -- Joint Venture shall be subject to VAT, even if the said purchases However, the purchases of goods/articles by WTG Construction & Development Furthermore, the following Deeds executed by the Landowner/s in favor of the Local

Extra Judicial Absolutc Sale Setttement of of a Parcel of with Deed of of a Portion an Estate Deeds Land Oct. 22 Date 2021 Heir/s of Azucena Landowner/s Ilustrisimo' Name of Tax Declaration NoS. Transferred (Sq. m.) 3.3 02 3.302 Area Brgy. Ocoy Santa Location Fc. (chu

: Sale of Jot only. regardless of the price, shall he subject to VAF starting January 01. 2021 pursuant to RA No. 10963. : This Certificate of Tax Exemption does not cover estate tax due, if any, on the estate of Azucena lustrisimo. : As adjusted using the 2010 Consumer Price Index values per Revenue Regulations (RR) No. 8-2021 dated June 11. 2021.

IVTG CONS. & DEY"T. CORP. /RDY CONSTRUCTOR - JV (Municipality of Sta. Fe Sites I & 2) CTE No.: Date issued: NSH - Je

Absolute Sale Extra Judicial Extra Judiciat Settlement of Absolute Sale Absolute Sale of a Parcel of Absolute Sale Extra Judicial Absolute Sale Settlement of Settlement of of a Parcel of of a Parccl of with Deed of Absolute Sale of a Portion with Deed of of a Portion with Deed of of a Portion an Estate an Estate an Estate Deed of Deed of Deed of Deeds Land Land Land Oct. 22 Oct. 22, Oct. 22 Oct. 22, Oct. 22. Oct. 22. 2021 202 Date 2021 202 202 2021 Heir/s of Lucrides Heir/s of Zosimo Heir/s of Maria P. Ilustrisimo4 P. llustrisimot Landowner/s Hlustrisimos Medmar T. (lustrisimo Rudico P. Name of Thelma I. Torrefiel Quijada Tax Declaration Nos. 'Transferred (Sq. m.) 10, S54 7.22 7.212 7.2!2 3.302 3.302 3.302 1.300 Area Brgy. Ocoy Santa Location Fe. Cebu

Absolute Sale Absolute Sale Deed of Decd of Nov: I7 Nov. 17 2021 202 Forrosuelo and Marietta Marfa Forrosuelo Sps. Roque Bulotano Sevilleno Elizabeth 30,719 5.401 Santa Fe. Cebu Brgy. Batidbid

and to VAT pursuant to Section 109 (1) (P) of the Tax Code of 1997, as amended. However. which shail be used for the above mentioned socialized housing project. are not subject to income tax/capital gains tax/expanded withholding tax pursuant to Section 20 of RA No. 7279 the Deeds are subject.to documentary stamp tax imposed under Section 196 of the Tax Code of 1997, as amended. hased on the actuai consideration of the properties transferred. considering that one of the contracting parties is the Government.

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

I.[ his Certificate of Tax Exemption does not cover estate tax due. if any, on the estate of Lucrides P. Hustrisimo. + This Certificate of Tax Exemption does not cover estate tax due. if any. on the estate of Zosimo P. Hustrisimo. This Certificate of Tax Exemption does not cover estate tax due, if any. on the estate of Maria Hlustrisimo.

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WTG CONS. & DEY"T. CORP./RDY (ONSTRUCTOR -JY {Municipulity of Sta. Fe Sites I & 2} Dute issueds CTE NO.: NSH :

be applied or are being applied to a socialized housing project pursuant to RA No. 7279. submitted. However, if upon investigation, the BiR ascertains that the facts are different, then this Certificate shall be considered nutl and void. Authorizing Registration (CAR). The CAR shall only be issued after submission of the complete requirements provided under Revenue Memorandum Order (RMO) No. 1 5-2003. the Register of Deeds having jurisdiction over the properties, to the effect that the same are to Upon application for exemption, a lien on the titles of the land shall be annotated by This CTE is being issued on the basis of the facts and documents as represented and Issued this day of DEC 1 6 3021

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K Commissioner of Internal Revenue CAESAR R. DULAY 0+7532 C

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