BIR Ruling No. 400-2021

REPUBLICOF THE PHHLIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No:

NSH - 400..2821

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that Biirey Construction/Eddmari Construction and Trading - Joint

project-related income taxes/creditable withholding tax(CWT) pursuant to'Section 20 (d) (1) of Repubiic Act (RA) No. 7279,as amended"by RA No."10884 (Balanced Housing Venture, an entity engaged by the National Housing Authority (NHA), is exempt from Development Program Amendments) dated July 17, 2016, on its income received directly in connection with the construction/procurement of 220 additional fully deveioped lots and completed housing units in Tingib Homes, a socialized housing project of the NHA under the NHA's Yolanda Permanent Housing Program, tocated at Brgy. Tingib, Pandan, Antique.

Moreover, the delivery of the said 220 additional fully developed lots and completed housing units shall be exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the Nationai Internal Revenue Code (Tax Code) of 1997, as amended, provided that the seiiing price thereof does not exceed P3,199,200.00 per house and lot package: provided further, that beginning January 01, 2021. the exemption from VAT shall oniy apply to sale of house and lot and other residential dwellings' with selling price of not more than P3.199.200.00.2

However, the purchases of goods/articles by Bilrey Construction/Eddmari Construction and Trading - Joint Venture, shail be subject'to VAT, even if the said purchases are to be used for the socialized housing project, since VAT is an indirect tax which

exempt official receipts on its gross receipts from the said socialized housing project. can be passed on by the seiler of the goods/services. It shall be understood that Bilrey Construction/Eddmari Construction and Trading - Joint Venture, must issue VAT-

favor of the NHA over the parcels of land described below, to wit: Furthermore, the Unilateral Deeds of Absolute Sale executed by the Landowner/s in

May 19 May i9 Date. 2016 2016 Candelaria Lazatin. married to Name of Landowner/s Desideria Sullivan I'omas Lazatin Certificate of Title Original (Sq. m.) 10.836 46.533 Area Transferred 18.763.87 (Sq. m.) 10.836 Area Location Pandan. Intique I'ingib. Brgy.

which shall be used for the above mentioned socialized housing project, is not subject to income tax/capital gains tax/expanded withholding tax and documentary stamp tax pursuant to Sections 19 and 20 of RA No. 7279 and to VAT pursuant to Section i09 (1) (P) of the Tax Code of 1997. as amended.

: As adjusted using the 2010 Consuner Price Index values per Revenue Regulations (RR) No. 8-2021 dated Jume 11. 2021. Sale of lot only, regardless of the price. shalt be subject to VAT starting Jamuary 01. 2021 pursuant to RA No. 10963

Bilrey Construction/Eddmari Construction and Trading - JV (Tingib Homes) CTE No.: Date issued: NSH - L00- 2021

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

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

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

Issued this day of_NOV 3 2021

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KI Commissioner of Internal Revenue CAESAR R. DULAY 046311

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