BIR Ruling No. 431-2019

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax E 0431-20 tion No:

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

PROPERTIES INC- JV (TIN: This certifies that EDDMARICONSTRUCTIONANDTRADING/KIT ., 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, 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 socialized housing units under the NHA's Yolanda Permanent Housing Program, to wit:

Date of Notice of Award Agreement Contract Date of Contract Price (Php) Project Name Location No. of Socialized Housing Units subject of tax exemption

November 3, 2016 April 2, 2018 Barasan-Bolilao People's. Village Dumangas, Iloilo Brgy. Barasan and Bolilao. 500

However, the purchases of goods/articles by EDDMARI CONSTRUCTION AND

TRADING/KIT PROPERTIES INC- JV 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 EDDMARI

CONSTRUCTION AND TRADING/KIT PROPERTIES INC- JV must issue VAT

Exempt official receipts on its gross receipts from the said socialized housing project.

Moreover, the Deed of Absolute Sale/ Unilateral Sale Executed by the Landowner in favor of the NHA over the parcels of land described below, to wit:

Date of Deed of Absolute January 29. Sale 2018 KIT PROPERTIES Landowner/Seller Name of INC. Certificate of Original Title No. (Sq. m.) 26,830 16,359 Area Transferred (Sq.m.) 38,000 Area Bolilao, Dumangas. Brgy. Barasan and Location Ioilo

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 Republic Act (RA) No. 7279

It is, however, understood that this 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

1 Portion of the area covered by TCT Nos.

EDDMARI CONSTRUCTION AND TRADING KIT PROPERTIES INC- JV CTENo. 0 L 3 1 - 2 0:1 9 Date issued _lll 3 0 2019 Page 2 of 2

name of the buyer without the necessary Certificate Authorizing Registration (CAR) issued by this Bureau. In this regard, this CTE 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 ascertain's that the facts are different, then this Certificate shall be considered null and void.

Issued this day of JUL 3 0 2019

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Commissioner of Internal Revenue CAESARR.DULAY

027.250

K-1-JAC