BIR Ruling No. 306-2020

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No. CMP-03a6-2020

CERTIFICATE OF TAX EXEMPTION

issued to

Gaudencio M.Mafialac Philippine Investment Two (SPV- AMC, Inc.represented by Carlos Name of Seller TIN Tower One, Ayala Avenue cor.Paseo de Unit 1603 (formerly at unit 1615Ayala Roxas,Makati City Address

-and

Name of Homeowners Association (HOA Maabi -Abihon Homeowners' Association Inc. TIN Maabi-abihon Brgy.Punta,Taytay,Bacolod City Negros Occidental Address

2019 over a parcel of land described below, to wit This certifies that the Deed of Absolute Sale enfered by the Seller and the HOA dated January 08

Certificate of Title Transfer (sq.m.) Area 3,510 Transferred s.m) 3,510 Area of CMP (sq.m.) 3,510 Brgy. Road, Punta, Taytay,Bacolod City,Negros Occidental Location

however,subject to documentary stamp tax under Section 196 of the 1997 Tax Code,as amended. being a Community Mortgage Program (CMP,is not subject to capital gains tax pursuant to Section 32 b) of Republic Act (RA)No.7279 or the Urban Development and Housing Act of 1992. The transaction is,

construed as giving authority to the concerned Register of Deeds to effect transfer of the land title in the name of the buyer without the necessary certificate of authority to register issued by this Bureau. In this regard, this Certificate shall be presented to the Revenue District Office (RDO concerned in order for the latter to issue the Certificate Authorizing Registration (CAR. The CAR shall only be issued after the submission of the requirements provided under Revenue Memorandum Order (RMO) No.15-2003 It is, however, understood that this Certificate of Tax Exemption is never intended and shall not be

entitled to exemption from capital gains tax or income tax imposed under Sections 24(D1and/or 27 (D5 occupants of the property transferred under the CMP are qualified beneficiaries and therefore,the seller is the 1997 Tax Code,as amended. The Bureau of Intermal Revenue (BIR) shall conduct verification and post-audit that the actual

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

Issued thisday of_JUN 0 8 2020

touraMrea

Commissioner of Internal Revenue CAESAR R.DULAY

035100 G K-M

Shall be proportionatecly distributed to the association's qualified member-beneficiaries (See Annex)