BIR Ruling No. 376-2021

REPUBLIC OF THE FHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No:

NSH . 376-2021

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

2000 Program, for delivery to the Republic of the Philippines. taxes/creditabie withholding tax (CWT) and value-added tax (VAT) pursuant to Section 20 (d) (1) and (3) of Republic Act (RA)`No. 7279, on its income received directly in connection with the development'of a forty-eight (48) hectare property located at Brgy: Muzon, City of San Jose Del Monte, Bulacan, consisting of 7,0451 socialized housing units also known as Pabahay This certifies that Filinvest Land, Inc. is exempt from project-related income

VAT, even if the said purchases are to be used for the above-mentioned socialized housing It shall be understood that Filinvest Land, Inc. must issue VAT-exempt official receipts on its gross receipts from the said socialized housing project. project, since VAT is an indirect tax which can be passed on by the seller of the goods/services. However, the purchases of goods/articles by Filinvest Land, Inc. shall be subject to

income tax/capital gains tax/expanded withholding tax and documentary stamip tax pursuant to executed by and between Filinvest Alabang, Inc.2, National Housing Authority (NHA), and the transfer of the said 7,045 socialized housing units also known as Pabahay 2000 Program Iocated at Brgy. Muzon, City of San Jose Del Monte, Bulacan, for administration and disposition to qualified beneficiaries on behalf of the National Government, is not subject to Sections 19 and 20 of RA No. 7279 Republic of the Philippines, where the NHA through its Board"of Directors accepted the Moreover, the Deed of Transfer and Acceptance dated June 26, 1998 made and

together with the documentary requirements provided under Revenue Memorandum Order intended and shall not be construed as giving authority to the concerned Register of Deeds (RD) to 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, (RMO) No. 15-2003, shall be presented to the Revenue District.Office (RDO) concerned in order for the latter to issue the CAR. 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_OCT._0_6_2021

KI-LMAT Commissioner of Internal Revenue CAESAR R. DULAY 046148 M

2 Appointed Attorney-in-fact of Filinvest Land, Inc. 1 While the Memorandum of Agreement dated February 12, 1997 entered into by and between"the Housing and Urban Resolution No. 3920 dated March 23, 1998. Development Coordinating Council (HUDCC), Public Estate Authority (PEA), and the NHA, where the President of the Philippines approved the recommendation of the NHA that it will adninister 7,093 socialized housing units at San Jose del Monte, Bulacan, the exemption from project-related income tax/CWT and VAT covers only income received directly in connection with the development of 7.045 socialized housing units per Deed of Transfer and Acceptance dated June 26. 1998 made and executed by and between Filinvest Alabang, Inc., NHA, and the Republic of the Philippines and the NHA