BIR Ruling No. 451-2021

REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE BUREAU Oj^IOTE]^^REVENUE Certifuate of^ax^Exem^i^n^No: HSU CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN: This certifies that HI-TRI DEVELOPMENT CORPOR^lTION,an entity engaged by the National Housing Authority(NHA)^ is exemptfrom 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 of250 socialized housing units in CDO Midland Valley Homes,a socialized housing project ofNHA Jinder the NHA's Community-Based Initiative Approach(CBIA)Program intended formerly for the members/families of the Armed Forces of the Philippines (AFP) and the Philippine National Police(PNP)butre-allocated to Qualified FormerRebel's Housing Project located at Brgy. Mambuaya,Dansolihon,Cagayan de Oro City. Moreover,the delivery ofthe said 250 socialized housing units shall be exempt from value-added tax(VAT)pursuant to Section 109(1)(P)ofthe National Internal Revenue Code of 1997 (Tax Code), as amended, provided that the selling price thereof does not exceed P3,199,200.00 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 dwellings^ with selling price ofnot more than P3,199,200.00^. However, the purchases of goods/articles by HI-TRI DEVELOPMENT CORPORATION shall be subject to VAT,even ifthe said purchases are to be used for the said 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 HI-TRI DEVELOPMENT CORPORATION must issue VAT Exempt official receipts on its gross receipts from the said socialized housing project. 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 DEC Q 9 202\ CAESAR R.DULAY K-l-MDT Commissioner cfInternal Revenue ^ Per Memorandum of Agreement dated November 12,2015. ^ 047686 r 2Sale oflot only,regardless ofthe price,shall be subject to VAT starting January01,2021 pursuant to RA No.10963. ^ As adjusted using the 2010 Consumer Price Index values per Revenue Regulation No.8-21321 dated June 11,2021.