BIR Ruling No. 298-2022

REPUBLIC OF THE PHILIPPINES

DEPARTMENT CE FINANCE BUREAU OF INTEENAL REVENUE

Quezon City

Certificate of Tax Exemption No:

NSH 298-2022

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that Shalom Construction, Inc., Hi entity engaged by the Nationa!

withholding tax (CWT) pursuant :to Section 20 (d) (1) cf Republic Act (RA) No. 7279, as Housing Authority (NHA), is exempt from projeei-related income taxes/creditable

amended by RA No. 10884 (Balarced Housing Developrient Program Amendments) dated Juiy 17, 2016, on its income received directly in connection with the acquisition/procurement

social.:ed housing project of the NHA'unuer the NHA's Yolanda Permanent Housing Program, of 479 fuily developed lots and comple'rd housing units:in Pandan Spring Subdivision, a

located in the Municipality of Pandan, Antique.

Moreover, the delivery of the said 479 fully developed lots and compicted housing units shali be exempt from value-added tax (VAT) pursuant to Section 109 (1)(P) of the National Internal Revenue Code (Tax Code) of 1997, as amended, provided that the seliing price thereof does not exceed P3,199,200.00 per house and 15t 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' valued at P3,199,200.00.2

subject to VAT, 'even if the said purchases are to be used for the above-mentioned socialized However, the purchases ot goods/articles by Shalom Construetion, Inc. shall be

housing project, since VAT is an indirect tax which can be passed on by the seller of the goods/services. It shail be understood that Shalom Construetion, Inc. must issue V AT-exempt official receipts on its gross receipts from the said socialized housing project.

Furthermore, the Deed of Absolute Sale made and executed by and between the Landowner/s and the NHA over the parcels of land descrihed below, to wit:

Date 2022 June 08 (Administrator/Beneficiat Name of Landowner/s (Herminia C. Fabella) (Teodolfo C. Gabor) (lsmael F. Candari) Bonifacio Candari Bonifacio Candari Bonifacio Candari Bonifacio Candari {Edgar C. Gabor) User) Tax Declaration (TD) No/s. Area Transferred (sq. m. Location

2 As adjusted using the 2010 Consumer Price I:dex values per Kivenue Regulrtions (RR) No. 8-2021 dated June 11, 2021. 1 Sale of lot only, regardless of the price, shall be subject to "t :tarting Jan iiry 01, 2021 pursuant to RA No. 10963. 3 Per TD No. the registered nar se of the Administrator/Benefic ial User is Teodulo C. Gabor, Jr.

(Pandan Spring Subdiviston) SHALOM CONSTRUCI , INC. CTE No. Date Issugd. E:298-2022 JUH -2 0 2922

which shall be used for the above mentioned socialized housing project, are not subjectt to income tax/capital gains tax/expanded withholding tax and documentary stamp tax pursuant tol

Sections 19 and 20 of RA No. 7279 and to VAT pursuant t. Section 109 (1) (P) of the Tax Code of 1997, as amended.

It is, however, understood that this Certificate of "Tz Exemption (CTE) is never intended and shall not be construed as giving authority io the concerned Register of Deeds/Assessors Office to effect transfer of the land titles in the name of the NHA without the necessary certificate of authority to register issued by this Bureau. In this regard, this CTE shall be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the Certificate Authorizing Registration (CAR). The CAR shall only be issued after submission of the complete requirements provided under Revenue Memorandum Order No. (RMO) 15-2003.

Upon application for exetaption, a lien on the titles cf the lands shall be annotated by. the Register of Deed/Assessors Office ha ing jurisdiction over the property, to the effect that the sam - are to be applied or are being app:ied to a socialized housing project pursuant to RA

No. 7279

This CTE is being issued on the basis of the facts and documents as tepresented and

submitted. However, if upon investigation, the BIR ascertains that the facts are different, then

this Certificate shall be considered null and vo'

Issued this . day of JUN 2 0 2022

MwaM CAESAR R. DULAY Commissioner of Internal Revenue 1051885{

K- I

4 This CTE does not inciude exemption from estite tax which'may be due, if any, on the estate of the deceased registered landowner/s PAGE 2 OF 2