bir_ruling BIR Ruling No. 274-2017BIR Ruling No. 274-2017

BIR Ruling No. 274-2017

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No:

CERTIFICATE OF TAX EXEMPTION

TO ALLWHOM IT MAY CONCERN:

This certifies that PERSAN CONSTRUCTION, INC. with Tax Identification Number

an entity engaged by the National Housing Authority (NHA), is exempt from project- related income taxes, creditable withholding tax and value added tax (VAT), pursuant to Section 20 d)(1) and (3) of Republic Act No. 7279, on its income received directly in connection with the construction/development of socialized housing units under the National Housing Authority (NHA)'s Yolanda Permanent Housing Program, to wit:

DATE OF NOTICE OF AWARD DATE OF CONTRACT AGREEMENT March 4,2015 July 6, 2015

PROJECT NAME CONTRACT PRICE (Php) LOCATION Concepcion People's Village-Site 1 Site I, Brgy. Bacjawan Norte, Concepcion, Iloilo NUMBER OF SOCIALIZED HOUSING 1,000 Housing Units UNITS SUBJECT OF TAX EXEMPTION

However, the purchases of goods/articles by PERSAN CONSTRUCTION, INC. 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 PERSAN CONSTRUCTION, INC. must issue non-VAT official receipts on its gross receipts from the said socialized housing projects.

Moreover, the Deed of Absolute Sale executed by the landowners in favor of the NHA over the parcel of land described below, to wit:

DATE OF DEED OF SALE June 18.2015 NAME OF LANDOWNERS/SELLERS Filipinas S. Sanares married to Danilo C. Sanares Luzviminda Berano married to Hannibal C. Berano Philip V. Santiago married to Charito M. Santiago

Capuchine S. Villarina married to Allan H. Amado V. Santiago Jr.

Ferdinand V. Santiago married to Raquel Santiago Villarina

Jimhuel V.Sabia David V.Sabia Solomon V. Sabia married to Susan T. Sabia

Moses V.Sabia Jessica V. Sabia

S

PERSAN CONSTRUCTION, INC. Concepcion People's Village-Site I Page 2 of 2 NH1-Yolanda Permanent Housing Program Date issued CTE No. 682017 274--2017

TRANSFER CERTIFICATE OF TITLE

LOCATION NO. AREA (SQ.M.) AREA TRANSFERRED Brgy. Bacjawan Norte, Concepcion, Iloilo 191,655 sq.m. 70.171 sq.m

which shall be used for the above-mentioned socialized housing project, is not subject to income

tax/capital gains tax/expanded withholding tax, docunentary stamp tax and value-added tax (VAT)

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 is never intended, and shall

not be construed, as giving authority to the concerned Register of Deeds to effect transfer of the land

titles in the name of the buyer without the necessary Certificate Authorizing Registration (CAR) issued

by this Bureau. In this regard, this Certificate of Tax Exemption shall be presented to the Revenue

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

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 JUN 08 2017

CAESAR R.DULAY Commissioner of Internal Revenue

006960

K-1VDPM14 Concepcion People's Village-Site 1 Persan Construction, Inc.

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