BIR Ruling No. 377-2022
REPUBLIC OF THE PHILIPPINES
BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE
Certificate of Tax Exemption No:
BOI -LEH - 3 7 7 - 2 0 ? 2
CERTIFICATE OF TAX EXEMPTION
TO ALL WHOM IT MAY CONCERN:
from income tax and creditable withholding tax on its income received directly in connection the Board of Investments (BOD) under Certificate of Registration No. Investments Code of 1987" and Section 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98, with its economic and low-cost housing project, Sabella Phase 2, consisting of 263 house and Iot units located at Brgy. Panungyanan, General Trias, Cavite, a project dulv registered with 04, 2020, for a period of three (3) years beginning from March 04, 2020 until March 03, 2023, pursuant"to Executive Order (EO) No. 226, otherwise known as the "Omnibus as amended. This certifies that CITIHOMES BUILDER AND DEVELOPMENT, INC. is exempt dated March
residential dwellings' with selling price of not more than P3,199,200.00.2 exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is 0l, 2021, the exemption from VAT shall only appiy to saie of house and lot and other Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and
registered with the BOI, if any (per HLURB License to Sell No. stores, offices, etc., shall be subject to the applicable taxes under the Tax Code of 1997, as house and lot units), including those units used for commercial purposes such as leasing, retail amended. However, the sale of house and lot units in excess of the 263 house and lot units the excess is 168
applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof. The Company is liable, however, for all other applicable taxes not discussed above. The grant of tax exemption herein is subject to the compliance with the provisions of
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 shali be considered null and void. This Certificate of Tax Exemption (CTE) supersedes CTE No. BOI-LEH-629-2020 and
Issued this day of AUG 2 5 2022
LILIA CATRIS GUILLERMO
K- I /21:85 Commissioner of.Internal Revenue 000367
2 As adjusted using the 2010 Consumer Price Index values per RR No. 8-2021 dated June ! 1. 2021 1 Sale of lot only, regardless of the price. shall be subject to VAT starting January 01. 2021 pursuant to RA No. 10963.
CITIHOMES BUILDER AND DEVELOPMENT, INC. {Sabella Phase 2} Date issued. CTE No.: BOI-LEH
OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS
l. The exemption "from income tax and creditabie withholding tax covers oniy income directly attributable to the revenues generated from the project, Sabella Phase 2, consisting of 263 house and lot units used solely for family home or dwelling purposes, located at Brgy. Panungyanan, General Trias, Cavite. Such exemption shall not cover revenues from units with selling price exceeding P2,000,000.00.
2. The Cormpany shail observe the following project time table:
Activity Schedule
Secure necessary license/permit/registration from Start of Commercial Operations Land acquisition Building/House Construction the government/training costs Site preparation and development March 2020 - December 2022 March 2016 -- February 2018 January.2018 -- June 202 1 March 2016 March 2020 3. In the computation of the project's ITH, interest income from in-house financing shall not be considered as revenues generated from the registered activity. 4. The Company's entitlement to ITH for its BQI-registered housing project is subject to the compliance with the provisions of the Specific Terms and Conditions of its BOI Registration. 5. Pursuant to Section 4 of Republic Act (RA) No.: 107083. the Company is required to file its tax exemptions, deductions, credits or exclusions from the tax base. as may be provided under EO Nol 226, within the periods prescribed under RA No. 10708's Implermenting Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. returns and pay its tax liabilities, on or before the deadline as provided under the Tax Code of 1997. as amended, using the electronic system for filing and payment of taxes of the BIR. It shall file with BOl a complete annual tax incentives report of its! income-based tax incentives, VAT and duty
6. The Company shall be constituted as a withholding agent for the government if it acts as employer or if it makes payments to individuals or corporations subject to the withholding taxes as source as by'RR No. 2-98, as amended. and any of its employees received compensation income subject to compensatior withholding tax, required under Chapter XIII and Section 57 of the Tax Code of 1997, as amended, and implemented
7. The Company is required to file on or before the t 5th-day of the fourth month following the ciose of Return under oath, stating its gross income and expenses incurred during the taxable year. its accounting period of a Profit and Loss Statement and Balance Sheet with the Annual Information
8. Finally, the Company's books of accounts and other pertinent records shall be subject to periodic and its tax liability, if any, pursuant to Section 235 iof the Tax Code of 1997, as amended. it is complying with the conditions under which it has been granted tax exemption or tax incentives examination by revenue enforcement officers of this Bureau for the purpose of ascertaining whether
3 An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by Investment Promotion Agencies.
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