BIR Ruling No. 382-2021

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF IN'TERNAL REVENUE

Nuezor City

Republic Act No.6657 BIR Ruling No.205-18 01-382-2021 UCT 1 T ZV2U

JAYVEE L. VICTORIA

Sir:

sale of a parcel iand, covered by Transfer Certificate of Title ("TCT") No. This refers to your ietter dated March 30, 2021, requesting for a ruling exemnting the by the Land Bank of the Philippines ("LBP") to JUANITO MANALASTAS, from payment of capital gains tax ("CGT") and documentary stamp tax ("DST") pursuant to Republic Act ("RA") No. 6657, otherwise known as the "Comprehensive Agrarian Reform Law of 1988 ".

Documents submitted disclosed that Juanito Manalastas is a farmer-beneficiary of a parcel of land identified as I.ot 56 pc:s-18411 with an area of 28,837 square meters, more or less, covered by TCT No. , located at Biclat, San Miguel, Bulacan, registered in the name of the LBP, covered by RA No. 3844 under Carlos Valerio Estate; that the subject property was transferred to Juanitc Manaiastas from the LBP through the execution of a Deed of Absolute Sale dated February 3. 2003; and that the Provincial Agrarian Reform Office ("PARO") of Bulacan certified that th sa:: Deed of Absolute Sale executed by and between LBP and Juanito Manalastas is covered b: Section 66 of RA No. 6657, in relation to RA No

3844.

In reply thereto, please be informed that the above transfer of land is exempt from the payment of CGT and DST pursuant to Section 66 of RA No. 6657, which provides:

"Section 66. Exemption fromi taxes and fees of Land Transfers. Transactions under this Act involving a iransfer of ownership, whether from natural or juridical persons, shall be exempted from taxes arising from capital gains. These transactions shall also be exempted from the paynent of registration fees. and all other taxes and fees for :he conveyance or transfer thereof. Provided. That all arrearages in real propert: taxes, without penalty or interest, shall be deductible from the compensation to which the owner may be entitled. "

Taking into consideration the Ceriification dated January 28, 2021 from the PARO of Bulacan, it appears that the instant transfer of the subject property, as evidenced by the Deed of Absolute Sale dated February 3, 2009 executed by and between LBP and Juanito Manalastas,

the same is exempt from the payment of CT and DST. is indeed covered by Section 66 of RA No. 6657, in relation to RA No. 3844. Consequently.l

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CT-3EZ-Za2T 20: : 1 202

Therefore, it is hereby rules thet thie sale of the subject land covered by TCT No. T. by the LBP to Juanito Manaiasias is exempt from the payment of CGT and DST pursuant to Section 66 of RA No. 6577

This ruling is being issued on the basis of the foregoing facts as presented. However, if upon investigation, it will be asccitained that the facts are different, then this ruling shall be considered null and void.

Very truly yours.

Ausawa

Commissioner of Internal Revenue CAESAR R. DULAY ht 046155

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K1-FR-21-0379

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