BIR Ruling No. 559-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNALREVENUE

00

LIPPY

rtificate of Tax Exemption No:

H0559-2020

CERTIFICATE OFTAX EXEMPTION

This certifies that the Deed of Absolute Sale (DOAS) executed by ATLANTICA

REALTY DEVELOPMENT CORPORATION in favor of the National Housing Authority (NHA) over the parcels of land deseribed below. to wit:

Date of Deed of Absolute Name of Sellers. Certificate of Transfer Area (sq. m.) Aggregate Transferred Area Location of Property

Novemher 5. 2019 Sale Developiment Corporation Atlantica Realty Title No. 12.285 Sq. m. 13.362 Sg. m. 12.285 S. m. [3.362 St. m. Lupa.Pandi. Mapulang Bulacan

with respect to the I square meter portion of the aforesaid lots. which shall be used for

the Pandi Village 2 (Expansion Area Resettlement Project, with 577 developed lots/housing units. located at Brgy. Mapulang Lupa, Pandi. Bulacan. a socialized housing project of the NHA intended for informal settler families affected by the Construction of the Harborlink Project Segment 0.Phase 2. of the Department of Transportation (DOTR) under the Build Build Program of the government. is not subject to creditable withholding tax/eapital gains tax, documentary stamp tax and value-added tax pursuant to Sections 19

and 20 of Republic Act (RA) No. 7279 and 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 the coneerned Register of Deeds to

Registration (CAR) issued by this Bureau. In this regard. this CTE., together with the documentary requirements provided under RMO No. 15-2003. shall be presented to the effect transter of the land titles in the name of the NHA without the Certifieate Authorizing

Revenue Distriet Office (RDO) concerned in order for the latter to issue the CAR.

Upon application for exemption, a lien on the title of the land shall be annotated by the Register of Deeds having jurisdiction over the properties, to the effect that the same is to be

applied or is being applied to a socialized housing project pursuant to RA 7279.

This Certificate of Tax Exemption is being issued on the basis of the 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 SEP 2 9 .2020

Msamm

Commissiouer of Internal Revenue CAESAR R.DULAY