BIR Ruling No. 621-2017

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE Quezon City

Certificate of Tax Exemption No. 62:-2017

CERTIFICATE OF TAX EXEMPTION

amended on June I5. 201I. executed by: This certifies that the donation under the Deed of Donation dated June 25. 2008, as

MAUNONG DEVELOPMENT (Formerly: L.aguna Properties Holdings. CORPORATION 'Inc.) BALIBAGO LAND CORPORATION AVIDA LAND CORPORATION Name of Donors TIN Greenfield Corporate Center. 88 United Street. Mandatuyong City Greenfield Corporate Center, 88 United Street, Greenfieid District. Mandaluyong City 1550 911.40" Street North," Bonifacio Triangle, Bonifacio Global City 1634.TaguigCity 1550 Address

in favor of:

covering the following properties: ROMAN CATHOLIC ARCHBISHOP Name of Donee OF LIPA TIN San Lorenzo Strcet. Mataas na Lupa,Lipa City 4217 Address

Certificates of Title (TCTs) Transfer {sq. m.) 20,000 2,500 2.500 5.000 Area and Lot 2 (20.817 square meters, more [Consolidated and subdivided into two (2) parcels of land denominated as Lot I (9.183 square meters, more or less). 30,000 square meters Aggregate Area or less) meters. more Donated (20.817 or less) square Lot 2 Area Batangas Location Antonio. Tomas. Sto. San

the donee for administration purposes. being a donation in favor of a religious organization, is exempt from the payment of the donor's tax pursuant to Section 101 (A) (3) of the National Internat Revenue Code of 1997. as amended. subject to the condition that not more than thirty percent (30%) of said gifts shall be used by

condition at the back of the tities because failure to comply with the said condition shall subject the donation to donor's lax. Since the donation involves parcels of land, the Register of Deeds shail annotate this

Documentary Stamp Tax Regulations, implementing Title Vil of thc Tax Code, provides that Moreover. Section 185 of Regulations No. 26. otherwise known as the Revised

AVIDA LAND CORPORATION, ET. AL. 13-78-3017 51-7017

conveyances of realties not in connection with a sale, to trustees or other persons without consideration are not taxable. Accordingly. the Deed of Donation is likewise not subject to the documentary stamp tax prescribed under Section 196 of the National Internat Revenue Code of 1997. as amended. but oniy to the documentary stamp tax of P15.00 imposed under Section 188 of the same Code.

registered real estate developers and"the donated properties are deemed ordinary assets. Thus. the transfer is considered as "transaction deemed'salc pursuant to Section 106 (B) (1) of the National Internai Revenue Code of 1997. as amended. as implemented by Section 4.106-7 of Revenue Regulations (RR) No. 16-2005. as amended. However. the donation is subject to vatue-added tax (VAT) since the donors are VA'T-

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

Issucd this day of DEC 1 8 2017

1&u8,onAy

Z K-I-LMAT Commissioner of Internat Revenue CAESAR R. DULAY 011769