BIR Ruling No. 427-2022

BUREAU OF INTERNALREVENUE REPUBLICOFTHE PHILIPPINES DEPARTMENT OF FINANCE

Certificate of Tax Eemption No SH-4272022 NO 1 2022

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN

exceed P3,199,200.002 per house and lot package; provided further, thateginning January 01, dwellings3 with selling price of not more than P3,199,200.00. homelessMoreover, the.delivery of 164(82 Duplex socialized housing units shall be exempt from value-added tax VAT pursuant to Section 1091(P of the National Internal Revenue Code of 1997 (Tax Code), as amended, provided that the selling price/value thereof does not 2021, the exemption from VAT shall only apply to sale of house and lot and other residential 7279, as amended by RA No.10884(Balanced Housing Development Program Amendments) tax and creditable withholding tax pursuant to Section 20d1of Republic ActRA No of 164 82 Duplex socialized housing units in Cagayan de Oro Housing Project located at BrgySan SimonCagayan de Oro City,under the Resettlement Assistance Prpgram for the ocal Government Unit of Cagayan de Oro Cityintended for the underprivileged and engaged by the National Housing Authority (NHAis exempt from project-related income dated July 17,2016,on its income received directly in connection with the housing construction This certifies that EDMOND RAY CONSTRUCTION AND SUPPLY,an entity

SUPPLY must issue VAT Exempt official receipts on its gross receipts from the said socialized housing project. socialized housing project, since VAT is an indirect tax which can be passed or by the seller of the goods/services. It shall be understood that EDMOND RAY CONSTRUCTION AND AND SUPPLY shall be subject to VAT, even if the said purchases are to be used for the However, the purchases of goods/articles by EDMOND RAY CONSTRUCTION

Government of Cagayan de Oro over the parcel of land described below, to wit Moreover, the Deed of Absolute Sale executed by the Landowner in favbr of the City

Date of Deed of Absolute May 07, 2021 Sale Josefina Lim Landowners Heirs of Name of ISellers Pung Certificate Original P of Title (Sq.m.) Area Transferred (Sq. m.) Area Location

and to VAT pursuant to Section 109 (1(P) of the Tax Code of .1997,as anended. The capital gains tax pursuant to Section 20 (d)(2) of Republic Act (RA) No. 7279.as amended, which shall be used for the above-mentioned socialized housing project is not subject to

3 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 1 Per Contract Agreement dated October 18, 2021. 2 As adjusted using the 2010.Consumer Price Index values per Revenue Regulation No.8-2021 dated June 1,2021. 4 Now TCT No. Iinder the name of the City Government of Cagayan de Oro.

Page 2 of 2 Edmond Ray Construction and Supply CTENO.NSH-272022 Date issuedNDV112022

of 1997, as amended, based on the actual consideration of the property transferred considering that one of the parties is the Government. transaction is, however, subject to documentary stamp tax under Section 196 of the Tax Code

this CTE, together with the documentary requirements provided under RMQ No.15-2003,shall be presented to the Revenue District Office (RDOconcerned in order for the latter to issue the CAR. effect transfer of the land title in the name of the City Government of Cagayan De Oro without the necessary Certificate Authorizing Registration(CAR issued by this Bureau.In this regard intended, and shall not be construed,as giving authority to concerned Register of Deeds to It is, however, understood that this Certificate of Tax Exemption TE is never

applied to socialized housing project pursuant to RA 7279. Register of Deeds having jurisdiction over the property,to the effect that the same is to be Upon application for exemption a lien on the title of the landshall be anhotated 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

K-1-JAC Commissioner of Internal Revenue LILIACATRIS GUILLERMO Ce 002409 Gl