BIR Ruling No. 335-2021

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: NSH-'3 35 -20 21

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that Edison Development and Construction, Inc., an entity engaged by. the National Housing Authority (NHA)', is exempt from project-related income taxes and creditable withholding tax pursuant to Section 20 (d)(1) of Republic Act (RA) No. 7279, as

dwellings3 with selling price of not more than P3, 199,200.00. intended for the families affected by Typhoon Yolanda under the NHA's Yolanda Permanent (Tax Code) of 1997, as amended, provided that the selling price thereof does not exceed P3,199,200.002 per house and lot package; provided further, that beginning January 01, 2021, amended by RA No. 10884 (Balanced Housing Development Program Amendments) dated July 17, 20 16, on its income received directly in connection with the construction/development of 631 socialized housing units in Mont Peak East located in Brgy. Baso, Cabucgayan, Biliran Housing Program. Moreover, the delivery of 631 socialized housing units shalt be exempt from value-added tax (VAT) pursuant to Section 109 (1)(P) of the National Internal Revenue Code the exemption from VAT shall only apply to sale of house and lot and other residential

housing project, since VAT is an indirect tax which can be passed on by the seller of the project. goods/services. It shall be understood that Edison Development and Construction, Inc. must issue VAT exempt official receipts on its gross receipts from the said socialized housing Inc., shall be subject to VAT, even if the said purchases are to be used for the socialized However, the purchases of goods/articles by Edison Development and Construction,

over the parcel of land described below, to wit: Moreover, the Deed of Absolute Sale executed by the Landowners in favor of the NHA

Date of Deed of Absolute Sa[e Landowners Name of Sellers Certificate of Title No. Transfer (Sq.n.) Area Transferred (Sq. m.) Area Location

February 13 2020 Lacandazo Salvacion Arendayen 30,000 1, 8 2

February 13. 2020 B. Salvatierra Sps. Oliva Arendayen Salvatierra and Wilfredo 14.408 13,803

1 Per Contract Agreement dated March 8, 2018. z As adjusted using the 2010 Consumer Price Index values 3 Sale of lot only, regardless of the price, shail be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. of the landowners for the sale of the properties identified and described in TCT Nos. 2nd 4 Special Powers of Attorney were executed in favor of Helen Igano Nadera to execute the Deed of Absolute Sale on behalf Revenue Regulation No. 8-2021

Edison Development and Construction, Inc. Page 2 of 2 CTE No.NS H.3 35 -Z 02 Date issued SEP_2 7_2021

February 13 2020 ( 1 c .. :: iano 29. 99 14,951

February 13: 2020 Arendayen Jennilita Lauriano 30.000 6,168 1,855

which shall be used for the above-mentioned socialized housing project, is not subject to capital gains tax and documentary stamp tax pursuant to Sections 19 and 20 of RA No. 7279, and to VAT pursuant to Section 109 (1)(P) of the Tax Code of 1997, as amended.

It is, however, understood that this Certificate of Tax Exemption (CTE) is never intended, and shall not be construed, as giving authority to concerned Register of Deeds 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, together with the documentary requirements provided under Revenue Memorandum Order (RMO) No. i5-

to issue the CAR. 2003, shall be presented to the Revenue District Office (RDO) concerned in order for the latter

applied or are being applied to a socialized housing project pursuant to RA No. 7279. Register of Deeds having jurisdiction over the properties, to the effect that the same are to be Upon application for exemption, a lien on the title of the land shall be annotated by the

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 7 Z&Z}

1048aM

K-1-JAC Commissioner of Internal Revenue CAESAR R. DULAY 045771