BIR Ruling No. 309-2021

REPUBLIC CF THEYHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No:

NSH -3 0 9 - 2 0 2 1

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that Kit Properties, Inc., an entity engaged by the National Housing

Authority (NHA), is exempt from project-related income taxes/creditable withholding tax

(CWT) 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 acquisition of 192 completed housing units in

Naga Permanent Housing Project, a socialized housing project of the NHA under the NHA's

Housing Program for Calamity Victims, located at Brgys. Tina-an and Inoburan, City of Naga,

Cebu.

Moreover, the acquisition of the said 192 completed housing units shail be exempt from

value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internai Revenue Code

(Tax Code) of 1997, 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 of not more than P3,199,200.00.2

However, the purchases of goods/articles by Kit Properties, Inc. 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 Kit Properties, Inc. must issue VAT-exempt official receipts on its gross receipts from the said socialized housing project.

This CTE 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 AUG 2 4 2021

tQU8O CAESAR R. DULAY Commissioner of Internal Revenue K- 044981

Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 2 As adjusted using the 2010 Consumer Price Index values per Revenue Regulations (RR) No. 8-2021 dated June 11, 2021