BIR Ruling No. 412-2022

REPUBLIC OF THE PHILIPPINES

G BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Certificate of Tax Exemption No:

PSH - 4T2- 2 022

CERTIFICATE OF TAX EXEMPTION

W S TO ALL WHOM IT MAY CONCERN:

T * exempt from income tax and creditable withholding tax (CWT) pursuant to Section 20 (d)(1) of Republic This certifies that ALSONS DEVELOPMENT AND INVESTMENT CORPORATION is

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 sale of socialized F house and lot units for residential and dwelling purposes to qualified beneficiaries in Molave Homes Alabel

Phase 2, consisting of 656 house and lot units, located at Brgy. Maribulan, Municipality of Alabel,

Sarangani Province, a project duly registered with the Department of Human Settlements and Urban Development (DHSUD) under Provisional Certificate of Registration No. and Provisional License to

indicated under said Provisional License to Sell.: Sell No. : provided that the selling price per house and lot package does not exceed the price ceilings

Likewise, the sale by Alsons Development and Investment Corporation of house and lots and other

residential dwellings valued at P3,199,200.00 and below, is exempt from value-added tax (VAT) pursuant

to Section 109 (1) (P) of the National Internal Revenue Code of 1997, as amended. Provided, however, that

beginning January 01, 2021, the exemption from VAT shall only apply to sale of house and lot and other

residential dwellings2 with selling price of not more than P3,199,200.00,3 and the sale of residential lot,

regardless of value, is now subject to VAT.

However, the purchases of goods/articles of Alsons Development and Investment Corporation shall

be subject to VAT, even if the said purchases are to be used for the above-mentioned 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 Alsons Development and Investment Corporation must issue VAT-exempt official receipts

on their gross receipts from the said socialized housing project.

Moreover, the Deed of Absolute Sale made and executed by and between the Seller and Alsons

Development and Investment Corporation over the parcel of land described below, to wit:

September 5, Date 2019 Name of Seller Company, Inc. Agricultural Sarangani (SACI) Certificate of Transfer Title No. (Sq. m.) Area Sqm. Transferre d (Sq. m) Sqm. Municipality of Maribulan. Sarangani Location Province Alabel, Brgy.

gains tax/expanded withholding tax pursuant to Section 20 of RA No. 7279 and to VAT pursuant to Section which will be used for the above mentioned socialized housing project, is not subject to income tax/capital 109 (1)(P) of the Tax Code of 1997, as amended.

2 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 1 See DHSUD Provisional License to Sell No. 3 As adjusted using the 2010 Consumer Price Index values per Revenue Regulations No. 8-2021 dated June 11, 2021. ated January 20, 2020.

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Page 2 of 3 Alsons Development and Investment Corporation CTE No. PSH- Date issued UCTTT 2U22 4 12 - 2 0 2 2

Ss S tax exemption clause in Section 20 of RA No. 7279. Thus, the documents conveying the properties shall be It is observed, however, that documentary stamp tax (DST) is not one of the taxes covered by the

in accordance with Section 6 (E) of the same Code, whichever is higher. Likewise, lots/units classified as Economic Housing, not being covered by RA No. 7279, shall be subject to the payment of appropriate subject to DST imposed under Section 196 of the National Internal Revenue Code of 1997, as amended, based on the consideration contracted to be paid for such realties or on their fair market value determined taxes.

BIR rules and regulations and the Terms and Conditions, which is attached hereto as Annex "A". The Company is liable, however, for other applicable taxes not discussed above. The grant of tax exemption herein is subject to the compliance with the provisions of applicable

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

Issued this day of OCT_1 1 2022

CalL

Commissioner of Internal Revenue LILIA CATRIS GUILLERMO

0019:45

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C K1-FR-21-0594 K

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Alsons Development and Investment Corporation Page 3 of 3 Date issued No. PSH- OCT11 2022 412-2022

ANNEX "A"

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the 656

TE uFma The developer shall submit the sworn statement of the buyer that he is socialized house and lot units located at Brgy. Maribulan, Municipality of Alabel, Sarangani Province.

eligible as a socialized housing beneficiary under Section 5 (A) of Revenue Regulations (RR) No. 11-97 to the Bureau of Internal Revenue (BIR) during the processing of the Certificate Authorizing Registration (CAR) for the transfer of the title of the socialized housing unit.

3 It is understood that the CAR shall only be issued after it is established upon

proper verification by the Revenue District Officer (RDO) concerned that. considering the rules on valuation of real property, the actual selling price per sale transaction of the socialized house and lot packages in this case does not exceed the price ceilings indicated under DHSUD Provisional License to Sell No. 003.

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