BIR Ruling No. 452-2021

KiirUJiL'L. UJb* imi I'irliUl'i'ilNJbO DEPAET>'lENT offinance BUREAU OFINTERNALREVENUE Quezon City Certificate No: CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN: This certifies that E.M. CUERPO,INC.(TIN: an entity engaged by the National Housing Authority (NBA), is exempt from project-related income tax, creditable withholding tax and value-added tax pursuantto Section 20(d)(1)and(d)(3)ofRepublic 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'ofTen (10)Five-Storey Medium Rise Buildings consisting of544 socialized housing units under the NHA's Socialized Housing Program, intended for the underprivileged and homeless families as well as those living in danger areas,to wit: Date of Date of Contract Price Project Name Location No. of Notice of Contract Socialized (Php) IPeasant Hills Award Agreement Subdivision, Housing Units subject of tax Ten (10) Five-Storey C ty ofSan Jose Del Monte, exemption March 1, October 24, 3 Medium Rise 2013' Bulacan 544 2013 Buildings with Land November 5, 20132 Development and Survey Works (Package 2) However,the purchases ofgoods/articles by E.M.CUERPO, INC.,shall be subject to VAT, even ifthe said purchases are to be used forthe socialized housing projept,since VAT is an indirecttax which can be passed on by the seller ofthe goods/services. It shall be understood that E.M.CUERPO INC., 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 0 9 2(liil . caes|rr.dulay Commissioner of Internal Revenue 047 681 K-l-JAC * Date acknowledged by NHA. . 'Date acknowledged by E.M.Cuerpo,Inc. '. 3 The Original Project Cost of Php296,888.333.88 was revised.'lS'Php3-18ib92;23g.80|or quantii ies overruns/underruns and extra works covered by Variation Order No.1issued by the NHA dated February 15,2016,which contract price was again adjusted to Php326,281,921.17 per Variation Order No. 2 dated August 15, 2016, and was revised to final Contract Cost amour ting to Php334,109,607.48 per Variation Order No.3dated December 6,2019.