bir_ruling BIR Ruling No. 428-2022BIR Ruling No. 428-2022

BIR Ruling No. 428-2022

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Certificate of Tax Exemption No: NSH-4 2 8- 707

NOV 11 2022

CERTIFICATEOFTAXEXEMPTION

TO ALL WHOM IT MAY CONCERN:

intended for the informal settlers and landless families residing along National Highway and only apply to sale of house and lot and other residential dwellings3 with selling price of not under the Resettlement Program for the Local Government Unit of Municipality of Don Carlos danger zone areas.Moreover, the delivery of 52 Serviced Homelots1 1 units developed lots and 41 socialized housing units shall be exempt from value-added tax (VAT pursuant to Section1091P of the National Internal Revenue Code Tax Code of 1997,as amended, providedthat the selling price/value thereof does not exceed P3,199,200.002 per house and lot packageprovided further,that beginning January 01,2021,the exemption from VAT shall more than P3,199,200.00. in NHA-Don Carlos Village Phase-I located at Brgy.Maraymaray, Don Carlos, Bukidnon tax and creditable withholding tax pursuant to Section 20 (d)(1) of Republic Act (RA) No. dated July 17,2016,on its income received directly in connection with the development/ construction of 52 Serviced Homelots:11 units developed lots and 41 socialized housing units engaged by the National Housing Authority (NHAis exempt from project-related income 7279, as amended by RA No.10884(Balanced Housing Development Program Amendments) This certifies that EDMOND RAY CONSTRUCTION & SUPPLYan entity

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

Government Unit of Don Carlos, Bukidnon over the parcel of land described below, to wit: Moreover, the Deed of Absolute Sale executed by the Landowner in favor of the Local

Date of Deed October 14, of Absolute 2019 Sale Landowners Name of ISellers m/to Certificate of Title No. Transfer (Sq.m.) 10,000 Area Transferred (Sq. m.) 10,000 Area Maraymaray Don Carlos Bukidnon Location Brgy.

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 July 13, 2020. 2 As adjusted using the 2010 Consumer Price Index values per Revenue Regulation No. 8-2021 dated June 11, 2021.

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Edmond Ray Construction& Supply Page 2 of2 CTENo.NSH-42820Z Date issued NOV12022

that one of the parties is the Government. transaction is,however,subject to documentary stamp tax under Section 196 of the Tax Code of 1997, as amended, based on the actual consideration of the property transferred considering which shall be used for the above-mentioned socialized housing project is not subject to capital gains tax pursuant to Section 20 d2) of Republic Act (RA No.7279,as amended and to VAT pursuant to Section 109 1P of the Tax Code of 1997, as amended.The

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

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

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

Commissioner of Internal Revenue LILIA CATRIS GUILLERMO chal O.Gulle

K-1-JAC 002408

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