CSE Builders/Studio26 Construction, Inc.-Joint Venture

March 24, 2021 CERTIFICATE OF TAX EXEMPTION NO. JV-085-21 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that CSE Builders/Studio26 Construction, Inc.-Joint Venture , an entity engaged by the National Housing Authority (NHA) , 1 is exempt from project-related income taxes and creditable withholding tax pursuant to Section 20 (d) (1) of Republic Act No. 7279, as amended by RA No. 10884 (Balanced Housing Development Program Amendments) dated July 17, 2016, on its income received directly in connection with the construction/development of 358 socialized housing units in Villa Verde Housing Project located in Brgy. Iligay, Villaba, Leyte, intended for the families affected by Typhoon Yolanda under the NHA's Yolanda Permanent Housing Program. Moreover, the delivery of 358 socialized housing units shall be exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code of 1997 (Tax Code), as amended, provided that the selling price thereof does not exceed P3,199,200.00 per house and lot package; provided further, that beginning January 01, 2021, the exemption from VAT shall only apply to sale of house and lot and other residential dwellings 2 with selling price of not more than P2,000,000.00. However, the purchases of goods/articles by CSE Builders/Studio26 Construction, Inc.-Joint Venture shall be subject to VAT, even if the said purchases are to be used for the socialized housing project, since VAT is an indirect tax which can be passed on by the seller of the goods/services. It shall be understood that CSE Builders/Studio26 Construction, Inc.-Joint Venture must issue VAT Exempt official receipts on its gross receipts from the said socialized housing project. Moreover, the Deeds of Absolute Sale executed by the Landowners in favor of the NHA over the parcels of land described below, to wit: Date of Deed of Sale Name of Landowner/Seller Original Certificate of Title No. Area (Sq.m.) Area Transferred (Sq.m.) Location October 15, 2019 AAA P-48150 40,055 20,987 Brgy. Iligay, Villaba, Leyte October 15, 2019 BBB CCC 3 P-48151 35,104 22,568 Brgy. Iligay, Villaba, Leyte October 15, 2019 DDD P-48152 47,800 7,315 Brgy. Iligay, Villaba, Leyte which shall be used for the above-mentioned socialized housing project, are not subject to capital gains tax and documentary stamp tax pursuant to Sections 19 and 20 of Republic Act (RA) No. 7279, and VAT pursuant to Section 109 (1) (P) of the Tax Code, as amended. ITAaHc 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 to effect transfer of the land titles in the name of the NHA without the necessary Certificate Authorizing Registration (CAR) issued by this Bureau. In this regard, this CTE, together with the documentary requirements provided under RMO No. 15-2003, 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 24th day of March, 2021. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. Per Contract Agreement dated November 29, 2018. 2. Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 3. This Certificate of Tax Exemption does not include exemption from estate tax on the transfer of OCT No. P-48151 from its registered owner, EEE, to his heirs.