BIR Ruling No. 323-2016

T BUREAU OF INTERNAL REVENUF REPUBLICOETHE PHILIPPINES DEPARTMENTOF HINANCE

Quezon City

RA7279

BIR Ruling No.243-2016

#323-2016 6-29-2016

3368 Harvard Street, Pinagkaisahan Makati City GOLDENVILLE REALTY AND DEVELOPMENT CORPORATION

Attention IDA ABENDANO-GUINTU

Gentlemen: President and General Manager

This refers to your letter dated June 9,2016.requesting issuance of Certificate of Tax Exemption for socialized housing project,theFully Developed & Completed

Tabuc/llaya.Panay.Capiz pursuant to Republic Act (R.A. No.7279, otherwise known as the"Urban Development and Housing Act of 1992 Housing Unitsunder NHA's Yolanda Permanent Housing Program located at Brgy

Documents submitted show that Carmela B.Jamora (hereinafter referred to as Landowner is the registered owner of a parcel of land with an area of One Hundred

Lot No.356-B of the subdivision plan, Psd-48323, being a portion of Lot 356 of the cadastral survey of Panay.G.LR.O Cad.Record No. Twenty Thousand Two Hundred Eighty square meters (120,280 sq.m.,identified as situated at Brgy. Pob.

conveyed the subject property to National Housing Authority (NHA (TIN Deed of Absolute Sale was executed whereby the Landowner transferred and Tabuc.Panay,Capiz and covered by Transfer Certificate of Title TCT No. issued by thc Registry of Deeds for Roxas,Capiz.On April 21.2015.a

at an agreed price of

is exempt from capital gains tax,documentary stamp tax and value-added tax: and that the above described property has been identified and certified for development into a residential project under the Yolanda Permanent Housing Program intended for the families affected by Typhoon Yolanda and qualified for housing assistance by Carmela B.Jamora to NHA of the property covered by TCT No under R.A.No.7279. In BIR Ruling No.003-2016 dated January 6,2016. it was ruled that the sale

042579

FormerlyTCT No

Goldenville Realty and Development Corporation Panay Ville Housing Project Page 2of3 6-29-2016 #323-2016

Goldenville Realty and Development Corporation (TIN Panay,Capiz-543 Housing Unitswith a contract price of Procurement of Fully Developed Lots and Completed Housing Units under the NHA's Yolanda Permanent Housing Program located at Site 2.Brgy.Ilaya/Tabuc, TheNHA has issued Notice of Award dated December 23.2015 to for the

of work under this project are Survey Works, Earthworks, Road Works. Drainage Developed Lots and Completed Housing Units (543 Units at Panay Ville Housing Project-Site 2.Brgy.Ilaya/Tabuc,Panay,Capiz was executed on February 4.2016 between NHA and Goldenville Realty and Development Corporation, whereby the latter is committed to deliver Five Hundred Forty Three (543 units (House and Lot Package) for a price of Works. Water System Electrical Power Lines, Miscellaneous Works and Housing Construction" To give effect to the Notice of Award.Contract for the Procurement of Fully and that according to the contract. the scope

No.7279,pertinent portions of which state that In reply, please be informed that pursuant to Section 20 of Republic Act (RA)

socialized housing and further reduce the cost of housing units for the benefit of the underprivileged and homeless, the following incentives shall be extended to the private sector: Housing. "Sec. 20. To encourage greater private sector participation in Incentives for Private Sector Participating in Socialized

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(d) Exemption from the payment of the following

(2 (3) ( Capital Gains Tax on raw tands used for the project. Value-added tax for the project contractor concerned:" Project-related income taxes.

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Project-Site 2, Brgy.Ilaya/Tabuc,Panay,Capiz and which was certified by the NHA Housing Units with its necessary construction components in Panay Ville Housing as a socialized housing project as resettlement site pursuant to R.A.7279.the income 543 Housing Units in Panay Ville Housing Project-Site 2. Brgy. Ilaya/Tabuc,Panay. Capiz shall be cxempt from project-related income taxes.(BIR Ruling No.243-2016 contractor whose services are engaged by NHA to undertake construction of 543 directly realized by Goldenville Realty and Development Corporation from the land development and housing construction with its necessary construction components for dated June 7. 2016) Considering that Goldenville Realty and Development Corporation is a project

Panay Ville Housing Project-Site 2,Brgy.Ilaya/Tabuc.PanayCapiz by Goldenville Realty and Development Corporation shall be exempt from VAT.However the construction with its necessary construction components for 543 Housing Units in Moreover. pursuant to Section 20 d3 of R.A.No.7279.the housing

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o ay d ement CorpotinPanayVile Hmg Proe n15 o

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puhaes f godvartice by Goldenville Realty and Development Corporation shall b snbiet to VAT.evon lf the sald purehases are to be used for the soeialized housing

pwet. stnee VAT is an indirect tax which can be passed on by the seller of the os services lt shall be understood that Goldenville Reaty and Development

Coporation must issue non-VAT official receipts on its gross receipts ffom the waid

socialiad housing project.

This ruling i being issned on the basis of the foregoing facts as represented

However.if upon investgationit will be disclosed that the facts are different.then

this nuling shall be considered null and void

Very truly yours.

M KIMS.JACINTO-HENARES

Commissionef of internal Revenue K-1-JRC 04257

JAUN 9 2815