BIR Ruling No. 619-2020

REPUBLIC OF THE-PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No.

DT~0619-2020

CERTIFICATE OF TAX EXEMPTION

issued to

Name of Donor TIN Address

SOUTH CITY HOMES INC. B2 L13 South City Drive, South City Homes Subd., Sto. Tomas, Bifian, Laguna 4025

This certifies that the donation under the Deed of Donation dated June 13, 2016,

executed by the donor in favor of:

Name of Donee TIN Address

(PHILIPPINE PROVINCE), INC. OBLATES OF SAINT JOSEPH Marauoy, Lipa City, Batangas 4217

covering the following properties, with improvements, to wit:

Nature of Property Transfer Certificate of Title Nos./Tax Declaration Nos. (sq.m.) Area Donated (sq.m. Area Location

Lot 5,768 5,768 South City Homes, Calabuso, Binan, Laguna

Lot 5,096 5,096 South City Homes, Calabuso, Bifian, Laguna

being a gift in favor of a religious corporation is exempt from the payment of the donor's tax pursuant to Section 101 (A)(3) of the Tax Code of 1997, as amended, subject to the condition that not more than thirty percent (30%) of said gift shall be used by the donee for

administration purposes.

The donation is, however, subject to value-added tax (VAT) since the donor is a

VAT-registered real estate developer and the donated properties are deemed ordinary assets, pursuant to Section 4.106-7 of Revenue Regulations No. 16-2005, the same being considered

a transaction deemed sale.

Moreover, Section 185 of Regulations No. 26, otherwise known as the Revised

Documentary Stamp Tax Regulations, implementing Title VII of the Tax Code, provides that

conveyances of realties not in connection with a sale, to trustees or other persons without

consideration are not taxable. Accordingly, the Deed of Donation is likewise not subject to

the documentary stamp tax prescribed under Section 196 of the Tax Code of 1997, as

amended, but only to the documentary stamp tax of P15.002 imposed under Section 188 of

the same Code.

1 Now Section 101 (A)(2) of the Tax Code of 1997 as amended by Republic Act No. 10963.

2 The old DST rate of 15.00 is used since the donation took place prior to the effectivity of R.A. No. 10963.

South City Hones, Inc.iOblates of Saint Joseph (Philippines "' Ovince), Inc Page 2 of 2 Date issued OCT 2 B 2020 CTE No.! DT-0635-2020

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. This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this day of. OCT 2 8 2020 wM

Commissioner of Internal Revenue CAESAR R.DULAY

K-1-JAC 037305