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Granby Trading & Construction

Certificate of Tax Exemption No. 352-18 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Mar 8, 2018

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March 8, 2018 CERTIFICATE OF TAX EXEMPTION NO. 352-18 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that GRANBY TRADING & CONSTRUCTION (TIN: 000-000-000-000), an entity engaged by the National Housing Authority (NHA), is exempt from project-related income taxes, creditable withholding tax, and value added tax (VAT), pursuant to Section 20 (d) (1) and (3) of Republic Act (RA) No. 7279, on its income received directly in connection with the construction/development of socialized housing units under the National Housing Authority (NHA)'s Yolanda Permanent Housing Program, to wit: Date of Notice of Award Date of Contract Agreement Contract Price (Php) Project Name Location No. of Socialized Housing Units subject of tax exemption February 01, 2016 March 23, 2016 ____________ Granville Residences-Site 1 Brgy. Bagacay, San Dionisio, Iloilo 1,000 units February 01, 2016 March 23, 2016 ____________ Granville Residences-Site 2 Brgy. Bagacay, San Dionisio, Iloilo 1,000 units However, the purchases of goods/articles by GRANBY TRADING & CONSTRUCTION shall be subject to VAT, even if the said purchases are to be used for the said socialized housing projects, 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 & CONSTRUCTION must issue VAT-exempt official receipts on its gross receipts from the said socialized housing projects. Moreover, the Deeds of Absolute Sale executed by the Landowner in favor of the NHA over the parcels of land described below, to wit: Date Name of Landowner Transfer Certificate of Title (TCT) Area (Sq.m.) Area Transferred (Sq.m.) Location May 24, 2016 AAA 1 represented by BBB by virtue of a Special Power of Attorney 2 dated October 8, 2015 TCT No. T-85594 73,776 3 73,776 Brgy. Bagacay, San Dionisio, Iloilo May 24, 2016 AAA represented by BBB by virtue of a Special Power of Attorney 4 dated October 8, 2015 TCT No. T-85594 64,684 5 64,684 Brgy. Bagacay, San Dionisio, Iloilo which shall be used for the above-mentioned socialized housing projects, is not subject to capital gains tax and documentary stamp tax (DST) pursuant to Sections 19 and 20 of RA No. 7279. 6 It is, however, understood that this Certificate of Tax Exemption (CTE) is never intended, and shall not be construed, as giving authority to the concerned Register of Deeds (RD) to effect transfer of the land titles in the name of the buyer without the necessary Certificate Authorizing Registration (CAR) 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 CAR. 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 8th day of March, 2018. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. Co-owner of a certain parcel of land covered by TCT No. T-85594 with an area of 831,828 square meters, more or less, one half (1/2) of which is considered her conjugal share with her late husband CCC who died sometime on November 26, 1986. An Affidavit of Ownership was submitted dated May 02, 2016 declaring ownership over her one half (1/2) conjugal share (under Doc. No. 131, Page No. 28, Book No. XL, Series of 2016, of DDD, Notary Public). 2. Under Doc. No. 54, Page No. 12, Book No. XXXIX, Series of 2015, of DDD, Notary Public. 3. Lot 3-B-4, of the subdivision plan, being a portion of Lot 3-B. 4. Under Doc. No. 54, Page No. 12, Book No. XXXIX, Series of 2015, of DDD, Notary Public. 5. Lot 3-B-5, of the subdivision plan, being a portion of Lot 3-B, which is part of the conjugal share of AAA. 6. The tax exemption does not cover estate tax due, if any, on the transfer of the properties from the deceased landowner (CCC) to his respective heirs.

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