bir_ruling BIR Ruling No. 538-2020BIR Ruling No. 538-2020

BIR Ruling No. 538-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: NCH-0538-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that MRRM TRADING & CONSTRUCTION with Taxpayers Identification Number (TIN , a private entity engaged by the National Housing.Authority NHA is exempt from project-related incometaxes, creditable withholding tax and value added tax (VAT,pursuant to Section 20 (d(1) and (3 of Republic construction/development of socialized housing units under the National Housing Authority Amendments dated July 17,2016, on its income received directly in connection with the (NHA)'s Yolanda Permanent Housing Program, to wit: Act (RA) No.7279,as amended by RA No.10884 (Balanced Housing Development Program

Notice of Date of Award Agreement Contract Date of Contract Price Project Name Location No. of Socialized Housing Units subject of tax exemption

December 16, 2015 June 24 2016 R Almeria Housing Project Site 1 Brgy. Jamorawon, Almeria, Biliran units

However, the purchasesof goods/articlesby MRRM TRADING &

CONSTRUCTION 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 MRRM TRADING & CONSTRUCTION

must issue VAT-exempt official receipts on its gross receipts from the said socialized housing

project.

Moreover, the Deed of Absolute Sale executed by the Landowner in favor of the NHA

over the parcel of land described below, to wit:

June 24, 2016 Absolute Sale Date of the Deed of Name of Landowner Elvira U. Blanco Certificate of Title (TCT) Transfer No. (Sq. m.) Area Transferred (Sq. m.) Area Brgy. Jamorawon, Almeria, Biliran Location

which shall be used for the above-mentioned socialized housing project, is not subject to capital

gains tax (CGT) and documentary stamp tax (DST) pursuant toSections 19 and 20 of RA'No.

7279.

It is, however, understood that this Certificate of Tax Exemption (CTE) is never CF

intended, and shall hot be construed, as giving authority to theconcerned Register of Deeds

Q

(Almeria Housing Project Site 1) MRRM TRADING & CONSTRUCTION CTENo.NS -0538 -2020 Date ssued_SEP 2 3 2020

be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the (RD) to effect transfer of the land titles in the name of the[buyer without the necessary Certificate Authorizing Registration (CAR) issued by this Bureau In this regard, this CTE shail CAR.

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

Issued this day of SEP 2 3 2020

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CAE$AR R. DULAY

KI-LMAT Commissioner of Internal Revenue 036514

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