BIR Ruling No. 478-2020
REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE
Quezon City
Certicate of Ta /xemption No Neh -
CERTIFICATE OF TAX EXEMPTION
TO ALL WHOM IT MAY CONCERN:
This certifies that CSE BUILDERS (TIN: ), an entity engaged by the
National Housing Authority (NHA), is exempt from project-related income taxes and
creditable withholding tax, pursuant to Section 20 (d)(1) of Republic Act No. 7279, as amended
by RA No. 10884 (Balanced Housing Development Program Amendments) dated July 17,
2016, on its income received directly in connection with the construction/development of
socialized housing units under the NHA's Yolanda Permanent Housing Program, to wit:
Date of Notice of Award Agreement Contract Date of Contract PriceProject Name (Php) Location No. of Socialized Housing Units subject of tax exemption
Sept. 19, 2017 Jan. 26, 2018 * San Antonio Homes Brgy. Linao, San Isidro, Leyte 144
However, the purchases of goods/articles by CSE BUILDERS shall be subject to VAT.
even if the said purchases are to be used for the 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 CSE BUILDERS must issue VAT Exempt official receipts on its gross receipts from the
said socialized housing project.
Moreover, the Deed of Sale executed by the Landowner in favor of the NHA over the
parcel of land described below, to wit:
March 7,2018 Date of Deed of Sale FERDINAND M. Name of Seller FABILE Original Certificate of Title No. (Sq.m.) Area Transferred (Sq. m.) Area Brgy. Linao, San Isidro, Leyte Location
which shall be used for the above-mentioned socialized housing project, is not subject to capital
gain tax and documentary stamp tax pursuant to Sections 19 and 20 of Republic Act (RA) No.
7279.
It is, however, understood that this CTE is never intended, and shall not be construed.
as giving authority to concerned Register of Deeds to effect transfer of the land titles in the
name of the buyer without the necessary Certificate Authorizing Registration (CAR) issued by
S
Page 2 of 2 CSE Builders - San Antonio Homes Date issued AUG 20 2020 CTE No. NH-0478-2020
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 CAR.
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. This Certificate of Tax Exemption is being issued on the basis of the facts and
Issued this day ofAUG 2 0 2020
CAESAR R.DULAY Commissioner of Internal Revenue
036325 K-1-JAC G
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