BIR Ruling No. 435-2021

&C/PFl^ REPUBLIC OF THE PHILIPPINE^ DEE^^BTMENT OF FINANCE BUREAU OFINTERNALREVENUE Quezon City Certificate of Tax Exemption No .4 S 5 - 2 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN: This certifies that the Deed of Absolute Sale (DOAS) dated September 14, 2021, executed by the Landowners in favor ofthe City Government ofCebu over the parcel ofland described below,to wit: Date of Deed Name of Transfer Area Area Location of Absolute Vendors Certificate Transferred of Title No. (Sq.m.) Sale' (Sq. m.) September Helen B. Potenciano 25,25^1 22,177 Quiot 14, 2021 Pardo, Samantha Angela B. Cebu City Potenciano Gene Marie B. Potenciano Norgene Paulito B. Potenciano which shall be used by the City Government ofCebu as a reloc;ation site in line with the City's continuing program ofgiving the underprivileged and homelesscitizensthe opportunityto own a lot at reasonable and affordable price through its SocializedH'ousing Program,is notsubject to capital gains tax pursuant to Section 20(d)(2)ofRepublic Act(RA)No.7279,as amended by RA No. 10884 (Balanced Housing Development Program Amendments) dated July 17, 2016. The transaction is, however,subject to documentary ^tamp tax under Section 196 of the National Internal Revenue Code of 1997,as amended,bas;d on the actual consideration of the property transferred considering that one ofthe parties is th<e Government. It is, however, understood that this Certificate of ax Exemption (CTE) is never intended, and shall not be construed, as giving authority to coi^cerned Register ofDeeds(RD) to effect transfer of the land title in the name ofthe buyer wIthout the necessary Certificate Authorizing Registration(CAR)issued by this Bureau.In this regard,this CTE,together with the documentary requirements provided under Revenue Memjjrandum Order(RMO)No. 15- 2003,shall be presented to the Revenue District Office(RDO)concerned in order for the latter to issue liie CAR. ^ Special Power of Attorney dated October 3,2017,was granted to Helen B. Potenciano to execute the Deed of Absolute Sale on behalf of the landowners.