BIR Ruling No. 277-2021

REPUBLIC OF THE PHLIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No:

NSH - 2 7 7 - 2 G 2 1

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

No. 7279, as amended by RA No. 10884 (Balanced Housing Development Program Residences, a socialized housing project of the NHA under the NHA's Community-Based 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) acquisition of 1,053 developed lots and completed housing units in Fountain of Beauty Initiative Approach for the benefit of the underprivileged families rendered homeless by recent typhoons including TS Usman, located at Brgy. Coyaoyao, Tigaon, Camarines Sur. Amendments) dated July 17, 2016, on its income received directly in connection with the This certifies that Rotaflex Construction and Development Corporation, an entity

January 01, 2021, the exemption from VAT shail only apply to sale of house and lot and other shall be exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National residential dwellings2 valued at P3,199,200.00. does not exceed P3,199,200.00' per house and lot package; provided further, that beginning Internal Revenue Code (Tax Code) of 1997, as amended, provided that the seiling price thereof Moreover, the acquisition of the said 1,053 developed lots and completed housing units

Corporation shall be subject to VAT, even if the said purchases are to be used for the above- However, the purchases of goods/articles by Rotaflex Construction and Development

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 Rotaflex Construction and Development Corporation must issue VAT-exempt official receipts on its gross receipts from the said socialized housing project.

Landowner/s and the NHA over the parcels of land described below, to wit: Furthermore, the Deeds of Absolute Sale made and executed by and between the

Date Landowner/s Name of Rotaflex Original/Transfer Certificate of Title No/s. Tax Declaration (TD) No/s. (sg. m.) Area Transferred (sq. m.) Location

June ol. June oI. 2021 2021 Construction and Construction and Development Development Corporation3 Corporation Rotaflex 50.003 31,626 3 1.626 50.003 Coy aoyao. Camarines Tigaon. Brgy. Sur

2 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 3 With Deed of Absolute Sale dated December 03, 2020 executed by and between the registered landowner. John Vincent + Per TD No. : As adjusted using the 2010 Consumer Price Index values per Revenue Regulations (RR) No. 8-2021 dated June 11, 2021. Cruz Molina. and Rotaflex Construction and Development Corporation. , the total area subiect of the sale is 50,003 square meters.

ROTAFLEX CONS. & DEV'T. CORP. (Fountain of Beauty Residences) Date issued: CTE NO.: NSH-.2 7 7 -.2_0 2 1

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

It is, however, understood that this Certificate of Tax Exemption (CTE) is never intended and shall not be construed as giving authority to the concerned Register of Deeds to effect transfer of the land titles in the name of the NHA without the necessary certificates 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 Certificates Authorizing Registration (CARs). The CARs shall only be issued after the submission of the complete requirements provided under Revenue Memorandum Order (RMO) No. 15-2003.

be applied or are being applied to a socialized housing project pursuant to RA No. 7279. 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 lands shall be annotated by

This CTE is being issued on the basis of the facts and documents as' represented and

this Certificate shall be considered null and void. submitted. However, if upon investigation, the BIR ascertains that the facts are different, then

Issued this day of_JUL.3 0_2021

DaG

K- Commissioner of Interna! Revenue CAESAR R. DULAY 044275

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