Stateland, Inc.

November 11, 2009 BIR RULING [DA-(DT-063) 663-09] 101 (A) (2); DA-019-2001; DA-302-2003; DA-328-2008 Stateland, Inc. 3/F, State Center Building 333 Juan Luna St., Binondo, Manila Attention: Mr. Bernardo M. Nicolas, Jr. Head-Prop. Acquisition & Processing Dept. Gentlemen : This refers to your letter dated March 18, 2009 requesting exemption from the payment of donor's tax on the donation of open spaces and road lots by Stateland, Inc. and E.M. Ramos Development Corporation in their subdivision project in Novaliches, Quezon City known as the "North Olympus IV", in favor of the Quezon City Government. In reply, please be informed that under Section 101 (A) (2) of the Tax Code of 1997, as amended, gifts made to or for the use of the National Government or any entity created by any of its agencies which is not conducted for profit, or to any political subdivision of the said Government are exempt from donor's tax. Considering that the donation of open spaces and road lots was made by Stateland, Inc. and E.M. Ramos Development Corporation in favor of the Quezon City Government, a political subdivision of the National Government, said donation, therefore, is exempt from donor's tax. (BIR Ruling Nos. DA-019-2001 dated February 15, 2001, DA-302-2003 dated September 16, 2003 and DA-328-2008 dated May 30, 2008) This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service