BIR Ruling No. 285-2022

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENTJE Quezon City

Certificate of Tax Exemption No: NSH - 2 8 5 2 022

CERTFICATE OF TAX EXEMPTION

TO ALI WHOM IT MAY CONCERN:

This certifies that Granby Trading and Construction, an 'ent:ty engaged by the Natior.! Housing Authority (NHA)', is exempt from project-related income taxes and creditable withholding tax pursuant to Section 20 (d)(1) of Rpublic Act (RA) No. 7279, as amended by RA No. 10884 (Balanced Housing Tavelopmerit Program Amendments) dated July 17, 2016, on its income received ditectly in co...ection with the construction/development of 928 socialized housing units in Naka-Buhi Paglaom Village located in Brgy. De La Fe, Buhi, Camarines Sur, intended for the qialified members of Naka-Buhi Paglaom Village Homeowners Association, Inc. (NBPVHOA) for the relocatior. and resettlement of the families affected by calamities and those living in danger areas under the Community-Based Initiative Approach (CBIA) of the NHA. Moreover, the delivery of 928 socialized housing units shall 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 thit the selling price thereof does not exceed P3,1 99,200.002 per house and lot package; provided further, that beginning January 01, 2021, the exemption from VAT: shall only apply to soite of house and lot and other residential dwellings3 with selling price of not more than P3,199,200.00.

be subject to VAT, even if the said purchases are to be used fer the socialized housing project, However, the purchases of goods/articles by Granby Trading and Construction, shall

since VAT is an indirect tax which can be passed on by the seller of the goods/services. It shall be understood that Granby Trading: and Construction must issue VAT exempt official receipts on its gross receipts from the :id socialized housing project.

Moreover, the Deeds of Absolute Sal executed by the is andowners in favor of the NHA over the parcels of land described belcvi, to wit:

Date of Deeds of Absolute March 5. 2021 Sale Editha A. Asence and Benjamin F. Landowner Name of ISeblers Asence of Title No. Certificate Original (Sq.m.) Area Transferred (Sq. m.) Area Location

1 Per Memorandum of Agreement executed by arid among Grandby Trading and Construction, NBPVHOA, and NHA da

Sale on behalf of the landowners for the sale of the properties identified and described in OCT Nos. 2 As adjusted using the 2010 Consumer Price Index.values per Revenue Regulatior. No. 8-2021 dated June 11, 2021. 3 Sale of lot only, regardless of the price, shall be subject to VAT starting January C1, 2021 pursuant to RA No. 10963 4 Special Powers of Attorney dated February 22, 20.1 was granted to Maria Sofia 3 LI.ana to execute the Deeds of Absolute December 11, 2020 and

(Naka-Buhi Paglaom Village) Granby Trading and Construction Page 2 of 2 Date issued - JUN -0 g -2022 CTE No 2 8 5 2.02 2

March 5, 2021 Belmonte and Abelardo H. Belmonte Adelia A.

which shall be used for the above-mentione-1 socialized housing project, is not subject to capital gains ta, and documentary stamp tax purs 'int to Sections 19 and 20 of RA No. 7279, and to VAT pursuant to Section 109 (1)(P) of the Tax Code of 199'i. as amended.

it is, however, understood that this Certificate of Tax Exemption (CTE) is never intended, and shall not be construed, as giving authority to concerned Register of'Deeds to effect transfer of the land titles in the name o ce buyer without the necessary Certificate Authorizing Registration (CAR) issued by this Bur'eau. In this regard, this CTE, together with the documentary requirements provided under Revenue Memorandum Order (RMO) No. 15- 2003, shall be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the CAR.

Upon applicaticn for exemption, a lien on the title of the land shall be annotated by the Register of Deeds having jurisdiction over the properties, to the effect that the same are to be applied or are being applied to a socialized housing project pursuant to RA No. 7279.

This CTE 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 shall be considered null and void.

Issued this day of JUN 0 8 2022

ARwM

CAESAR'R. DULAY

K-I-JAC Commissioner of Internal Revenue T 051770