BIR Ruling No. 396-2021

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU ORIINAERNXL REVENUE

Certificate of Tax Exemption No: NsH33e-2oT

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that BAQUE CORPORATION, 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 amended by RA No. 10884 (Balanced Housing Development Program Amendments) dated July 17, 2016. on its income received directly in connection with the construction/development of 767 socialized housing units in La Vista de Calamba, a socialized housing project of NHA under the NHA's Community--Based Initiative Approach (CBIA) Program intended for the families affected by the Supreme Court Mandamus, located at Brgy. Banlic, Calamba City, Laguna.

Moreover, the delivery of the said 767 socialized housing units shall be exempt from value-added tax (VAT) pursuant to Section 109 (1)(P) of the National Internal Revenue Code of 1997 (Tax Code), 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, the exemption from VAT shall only apply to sale of house and lot and other residential dwellings3 with selling price of not more than P3, 199,200.00.

The purchases of goods/articles by BAQUE CORPORATION shall 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 can be passed on by the seller of the goods/services. It shall be understood that BAQUE CORPORATION must issue VAT Exempt official receipts on its gross receipts from the said socialized housing project.

Moreover, the Deed of Conveyance executed by the Landowners in favor of the NHA over the parcels of land described below, to wit:

Date Name of Landowner/s Original/Transfer Certificate of Title (Sq.m.) Area 1 Transferred Area Location

May 31, 2021 Remedios C. Arambulo: Manuel C. Arambulo, Jr. married Rodolfo C. Arambulo married to Rosario C. Arambulo; Virgilio C. Arambulo married to Ruth G. Orsolim; Zoilo Zablan; to Lilia Torres; Elvira Senga: Teresita A. Zablan married to Seller/st No. 46,643 (Sq. m.) 46,643

1 Per Memorandum of Agreement dated May 21, 2021 2 As adjusted using the 2010 Consumer Price Index values per Revenue Regulation No. 8-2021. 3 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 4 As represented by Teresita Ruby Arambuio-San Juan.

Page 2 of 2 BAQUE CORPORATION/La Vista de Calamba Homeowners Association CTENo. NM- 3 96-2_:. Date issued OCT. 2 5 221

Myrcia A. Viado married to Lydia A. Golez married to Manuel Golez; Erlinda A. Silva married to Federico Viado:

Ernesto R. Arambulo; Edgardo R. Arambulo: Heirs of Nestor C. Arambulo Encarnita R. Arambulo; and Arturo Silva; Eduardo R. Arambulo

May 20, 2021 married to Victor Jorvina Josefina Arambulo 25,000 25,000

which shall be used for the above-mentioned socialized housing project, is not subject to capital gains tax and documentary stamp tax under Sections 19 and 20 of RA No. 7279, as amended, and to VAT pursuant to Section 109 (1)(P) of the Tax Code, 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 NHA without 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 be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the CAR.

the Register of Deeds having jurisdiction over the properties, to the effect that the same are to be applied or are being applied to a socialized housing project pursuant to RA 7279. Upon application for exemption, a lien on the titles of the iand shall be annotated by.

This CTE 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 OCT 2 -5 2021

wsa/y CAESAR R. DULAY Commissioner of Internal Revenue I 046625 K-1-MDT