BIR Ruling No. 270-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No:

PSH-0270 -2J20

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

creditable withholding tax (CWT) pursuant to Section 20 (d) (1) of Republic Act (RA) No. dated July 17,2016, on its income received directly in connection with its sale of socialized house and lot units for residential and dwelling purposes to qualified beneficiaries in 7279, as amended by RA No. 10884 (Balanced Housing Development Program Amendments) Primerarosa Residences, consisting of 1,973 house and lot units and 1 lot, located at Brgy. Sta. Teresita, Sto. Tomas, Batangas, a project duly registered with the Housing and Land Use Regulatorv Board (HLURB) under Certificate of Registration No. and lot and P180,000.00 per lot onlyl. Taxpayers Identification Number (TIN) No. This certifies that SUMMERHILLS HOME DEVELOPMENT CORP. with provided that the selling,price of said units does not exceed P450,000.00 per house , is exempt from income tax and and License to Sell

Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and below, or house and lot and other residentiai 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 dwellings?

with selling price of not more than P2,000,000.00.

It is observed, however, that documentary stamp tax (DST) is not one of the taxes

covered by the tax exemption clause in Section 20 of RA No. 7279. Thus, the documents conveying the properties shall be 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 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 taxes.

The grant of tax exemption herein is subject to the compliance with the provisions of applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof. The Company is liable, however, for other applicable taxes not discussed above.

This Certificate of Tax Exemption 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_MAY 2 6 2020

Aaae

CAESAR R.DULAY Commissioner of Internal Revenue K-1-LMAT 035089

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Sale f lot ony,regardless of the pricehll be subject toVAT sarting January 1,201 pursuant to RA No.10963. Per HLURB License to Sell No. 031418 dated August 15, 2016.

SUMMERHILLS HOME DEVELOPMENT CORP (Primerarosa Residences) Date i3sued: MAY 2 5 202Q CTE No.: PSH - 0270-2020

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

1. The exemption from income and creditable withholding taxes covers only income directly

attributable to the revenues generated from the 1,973 socialized house and lot units and 1

socialized lot in Primerarosa Residences, located at Brgy. Sta. Teresita, Sto. Tomas, Batangas.

2 The developer shall submit the sworn statement of the buyer that he is 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.

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 really exceed P450,000.00 and P180,000.00 per lot only.

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