bir_ruling BIR Ruling No. 525-2020BIR Ruling No. 525-2020

BIR Ruling No. 525-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: D01-LEH-0525-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

whichever is earlier, but in no case earlier than the date of registration of the project with the Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations No. 2-98, as amended. Identification Number withholding tax on its income received directly in connection with its economic and low-cost housing project (horizontal), WESTWOOD PHASE 3, consisting of 504' house and lot units located at Brgy.Pasong Camachile, General Trias, Cavite. a project duly registered with the of 3 years beginning from July 2017 or actual start of commercial operations/selling. Board of Investments (BOI) under Registration No. BOI, pursuant to Executive Order No. 226, otherwise known as the "Omnibus Investments This certifies that PROPERTY COMPANY OF FRIENDS, INC., with Tax is exempt from income tax and creditable dated July i3, 2017, for a period

below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is VAT-exempt under Section 109(1)(P) of the 1997 Tax Code, as amended. Provided, however, that beginning January 1, 2021, the VAT exemption shall apply only to sale of house and lot (P2,000,000.00). and other residential dwellings2 with selling price of not more than Two Million Pesos Moreover, the sale by the Company of residential lots valued at P1,919,500.00 and

for commercial purposes such as leasing, retail stores, offices, etc., shall be subject to the Sell No. The sale, however, of housing units in excess of the 504 units (per HLURB License to , the excess is 14 units) registered with the HLURB, including those units used

applicable taxes under the 1997 Tax Code, as amended.

The grant of tax exemption herein is subject to the compliance with the provisions of

The Company is liable, however, for all other applicable taxes not discussed above. applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof.

documents as represented and submitted. However, if upon investigation, the BIR ascertains This Certificate of Tax Exemption is being issued on the basis of the facts and

that the facts are different, then this Certificate shall be considered null and void.

Issued this day of SEP 1 5 2020

aeowv

CAESAR R. DULAY Commissioner of Internal Revenue

K- 036705 Aa

2 Sale of lot only, regardless of the price, shall be subject to VAT starting January I, 2021 pursuant to RA No. 10963. Based on HLURB License to Sell No.

Property Company of Friends, Inc. CTENo.bO1-LEH0 525 -2 0 20

Page 2 of 2 Date issued SEP 1 5_2U2U

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1.The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, WESTWOOD PHASE 3, consisting of 504 house and lot units located at Brgy. Pasong Camachile, General Trias, Cavite. Such Moreover, the 504 units shall not be sold for more than P1,700,000.00 per house and lot based exemption shall not cover revenues from units with selling price exceeding P3,000,000.00. on HLURB License to Sell No.

2. The Company is obligated to construct and sell 5183 housing units based on the following schedules/sales revenues:

Year Volume Value

(No. of Units)

2 207 156

155 Total 518

3. In the computation of the project's ITH, interest income from in-house financing shall not be

considered as part of the revenues generated from the registered housing project.

4.The Company's entitlement to ITH for its BOI-registered housing project is subject to the

compliance with the provisions of the Specific Terms and Conditions of its BOI Registration.

5. Pursuant to Section 4 of Republic Act (RA) No. 107084, the Company is required to file its tax

returns and pay its tax liabilities, on or before the deadline as provided under the 1997 Tax Code, as amended, using the electronic system for filing and payment of taxes~of the BIR. It shall file with BOI a complete annual tax incentives report of its income-based tax incentives, VAT and duty exemptions, deductions, credits or exclusions from the tax base, as may be provided under E.O. 226, within the periods prescribed under R.A. 10708's Implementing Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016.

6. The Company shall be constituted as a withholding agent for the government if it acts as

employer and any of its employees received compensation income subject to compensation

withholding tax, or if it makes payments to individuals or corporations subject to the

withholding taxes as source as required under Chapter XIII and Section 57 of the Tax Code of

1997, as amended and implemented by Revenue Regulations (RR) No. 2-98, as amended.

T The Company is required to file on or before the 15t day of the fourth month following the

close of its accounting period of a Profit and Loss Statement and Balance Sheet with the Annual

Information Return under oath, stating its gross income and expenses incurred during the

taxable year.

8.Finally, the Company's books of accounts and other pertinent records shall be subject to

periodic examination by revenue enforcement officers of this Bureau for the purpose of

ascertaining whether it is complying with the conditions under which it has been granted tax

exemption or tax incentives and its tax liability, if any, pursuant to Section 235 of the Tax Code

of 1997,as amended.

While the number of units registered with BOI is 518, only 504 units registered with the HLURB shall be

covered by the tax exemption certificate.

+ An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by

Investment Promotion Agencies.

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