BIR Ruling No. 453-2021

^rpFi^ REPUBUC OFTHEPHILIPPINES DEEARIMENT OF FINANCE BUKEAU OFINTERNAL REVENlUE Quezon City CertiTicate ofTax Exemption No: MSi4-i 45S - ZQ Z1 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN: This certifies that E.M. CUERPO,INC.(TIN: )), an entity engaged by the National Housing Authority (NHA), is exempt from project-related income tax, creditable withholding tax and value-added tax pursuantto Section 20(d)(1)and(d)(3)ofRepublic Act(RA)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/developmentofTwo (2) Five-Storey Medium Rise Buildings consisting of 120 socialized ijousing units under the NHA's Socialized housing Program,intended forthe ynderprivileged and home essfamiliesorInformal Settler Families(ISFs)residing within the Manggahan Floodway Channel,to wit: Date of Date of Contract Price Project Name Location No. of Notice of Contract Socialized (Php) Manggahan Award Agreement Residences Phase I, Housing Units i East Embankment, subject oftax January July 3, Manggahan Floodway 24,2013 2013' exemption July 4, 2013^ Brgy. Sta. Lucia, 120 Pasig City However,the purchases ofgoods/articles by E.M.CUERPO, INC.,shall be subject to VAT, evfen ifthe said purchases are to be used for the socialized housing project,since VAT is an indirecttax which can be passed on by the seller ofthe goods/services. It shall be understood that E.M.CUERPO INC., must issue VAT Exempt official receipts on its gross receipts f~rom the said socialized housing project. This Certificate ofTax Exemption is being issued on the basis ofthe facts and 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. Issued this day of K-l-JAC CAESAR R.DULAY Commissioner^^fInternal Revenue 047680 ^ Date acknowledged by E.M. Cuerpo, Inc. 'Date acknowledged by NHA. 'The Original Project Cost of PhpSS,073,888.33 was revised to Php60,490,636.35 for additional works and additional contract duration .covered by Variation Order Nos.1 and 2issued by the NHA dated March 14,2014 and July 27,2014,respectively,which contract price was again adjusted to Php61,592,072.35 per Variation Order No.3dated February 20,2015,and was revised to finai Contract Cost amounting to Php61,499,200.46 per Variation Order No.4 dated January 10,2019.