BIR Ruling No. 301-2021

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: NCH-31-20Z

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that PHINTECSTAR CONSTRUCTION,INC.,an entity engaged by the National Housing Authority (NHA), is exempt from 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 of 8872 socialized housing units in Ormoc Highlands 1 and 2 located at Brgys. Gaas and Dolores, Ormoc City, Leyte, intended for the families displaced by the Magnitude 6.5

exempt from value-added tax (VAT) pursuant to Section 109 (1)(P) of the National Internal Earthquake in the Visayas. Moreover, the delivery of 887 socialized housing units shall be Revenue Code of 1997 (Tax Code), as amended, provided that the selling price thereof does

residential dwellings4 with selling price of not more than P3,199,200.00. not exceed P3,199,200.003 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

The purchases of goods/articles by PHINTECSTAR CONSTRUCTION,INC.shall

since VAT is an indirect tax which can be passed on by the seller of the goods/services. It shall be understood that PHINTECSTAR CONSTRUCTION,INC.must issue VAT Exempt be subject to VAT,even if the said purchases are to be used for the socialized housing project. official receipts on its gross receipts from the said socialized housing project.

favor of the LGU-Ormoc City over the parcels of land described below, to wit: Moreover, the Deeds of Absolute Sale/Unilateral Sale Executed by the Landowners in

Deeds of Absolute Date of Sale Landowners Name of ISellers Certificate of Title Original/Transfer No. (Sg.m.) Area Transferred (Sq. m.) Area Location

December 13, 2017 Belmoro and Sps.Alberto Diosdada F. 13,587 13,587

Belmoro

2 Y

2The number of units was increased from the original 792 house and lot units to 887 per Variation Order No.1 issued by the 3 As adjusted in 2011 using the 2010 Consumer Price Index values per Revenue Regulation No. 8-2021. 4 Sale of lot only,regardless of the price,shall be subject to VAT starting January 01,2021 pursuant to RA No.10963 1Per Contract Agreement dated October 23,2018. NHA dated October 31,2018.

Page 2 of 2 Phintecstar Construction, Inc./Ormoc Highiands 1 & 2 Date issued AUGQ2021 CTE No. NS - 3 6 1 - 2 0 Z 1

June to. 2018 Belmoro and Diosdada F. Sps.Alberto Belmoro 39,429 19,161

11, 2018 October Abraham Perezs 78, 960 78, 960

11, 2018 October Arleen May Perez 78, 61 78.961

the actual consideration of the property transferred considering that one of the parties is the subject to documentary stamp tax under Section 196 of the Tax Code, as amended, based on Government. capital gains tax under Section 20 (d)(2) of RA No. 7279, as amended by RA No."10884 pursuant to Section 109 (1)(P) of the Tax Code, as amended. The transaction is, however. which shall be used for the above-mentioned socialized housing project, is not subject to (Balanced Housing Development Program Amendments) dated July 17, 2016, and to VAT

the documentary requirements provided under RMO No. 15-2003, shall be presented to the intended, and shall not be construed, as giving authority to concerned Register of Deeds to Revenue District Office (RDO) concerned in order for the tatter to issue the CAR. effect transfer of the land titles in the name of the NHA without the necessary Certificate Authorizing Registration (CAR) issued by this Bureau. In this regard, this CTE, together with It is, however, understood that this Certificate of Tax Exemption (CTE) is never

Submitted. However, if upon investigation, the BIR ascertains that the facts are different, then this Certificate shall be considered null and void. This CTE is being issued on the basis of the facts and documents as represented and

Issued this day of AUG 1 0 202f

10a

K-1-JAC Commissioner of Internal Revenue CAESAR R. DULAY W 044576 G (

Absolute Sale on behalf of Abraham P. Perez for the sale of the property identified and described in TCT No. 5 Special Power of Attorney dated March 23, 2018, was granted to Arleen May Perez Figurasin to execute the Deed of