BIR Ruling No. 002-2022

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNALREVENUE

Quezon City

Certificate of Tax Exemption No: PsH2a2empt

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

Government of San Miguel, Leytel, is exempt from project-related income taxes and This certifies that Verlin Konstrukt, Inc., an entity engaged by the Municipal

creditable withholding tax pursuant to Section 20 (d)(1) of Republic Act (RA) No. 7279, as amended by RA No. 10884 (Balanced Housing Development Program Amendments) dated of 480 socialized housing units in Design and Build Scheme Project located at Brgys July 17,2016,on its income received directly in connection with the construction/development

Malaguinabot and Malpag, San Miguel, Leyte, intended for the families affected by Typhoon 109 (1)(P) of the National Internal Revenue Code of 1997 (Tax Code), as amended, provided Yolanda under the NHA's Yolanda Permanent Housing Program. Moreover, the delivery of 480 socialized housing units shall be exempt from value-added tax (VAT) pursuant to Section

provided further, that beginning January 01,2021, the exemption from VAT shall only apply that the selling price thereof does not exceed per house and lot package;

to sale of house and lot and other residential dwellings3 with selling price of not more than

VAT, even if the said purchases are to be used for the socialized housing project, since VAT However, the purchases of goods/articles by Verlin Konstrukt, Inc. shall be subject to

is an indirect tax which can be passed on by the seller of the goods/services. It shall be understood that Verlin Konstrukt, Inc. must issue VAT Exempt official receipts on its gross receipts from the said socialized housing project.

Moreover, the Deeds executed by the Landowners in favor of the Municipality of San Miguel, Leyte over the parcels of land described below, to wit:

Deeds Date Landowner/s Name of Seller/s of Title No. Certificate Original (Sq.m.) Area Transferred (Sq. m.) Area Location

Estate with Deed of Absolute Sale Extra-Judicial Settlement of November 3, 2021 Ramil G.Agner Shirley G. Antoni Lesigues Letecia G.Abala Ruben G.Agner Remedios G. Malaguinabot, San Miguel, Leyte Brgy.

Leo G.Gesma

U 2 As adjusted using the 2010 Consumer Price Index values per Revenue Regulation No. 8-2021 dated June 11, 2021. 1 Per Contract Agreement dated February 22, 2019.

3 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963.

F

Verlin Konstrukt, Inc. /Design and Build Scheme Page 2 of 2 Date issued JAN 1 0_2022 CTE No. PCiH002-2022

Estate with Deed of Absolute Sale of Unsegregated Extra-Judicial Settlement of Portion February 22, 2019 Gil D. Balais Romulo D. Balais Maria Grace D. Balais4 Anunciasion Balais Edgardo D. Balais Brgy. Malpag. San Miguel, Leyte

which shall be used for the above-mentioned socialized housing project is not subject to capital Internal Revenue Code of 1997, as amended, based on the actual consideration of the property 10884 (Balanced Housing Development Program Amendments) dated July 17, 2016. The transaction is, however, subject to documentary stamp tax under Section 196 of the National transferred considering that one of the parties is the Government. gains tax pursuant to Section 20 (d)(2) of Republic Act (RA) No. 7279, as amended by RA No.

intended, and shall not be construed, as giving authority to concerned Register of Deeds to this CTE, together with the documentary requirements provided under RMO No. 15-2003, shall be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the effect transfer of the land titles in the name of the Municipality of San Miguel, Leyte without the necessary Certificate Authorizing Registration (CAR) issued by this Bureau. In this regard, CAR. It is, however, understood that this Certificate of Tax Exemption (CTE) is never

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 JAN 1 02022

eesawa

Commissioner of Internal Revenue CAESAR R. DULAY

K-1-JAC 048423

4 This Certificate of Tax Exemption does not include exemption from estate tax on the transfer of OCT No. TC-43635 from its registered owner, Jesus Balais, to his heirs.