Certificate of Tax Exemption No. NSH-0656-2020

December 2, 2020 CERTIFICATE OF TAX EXEMPTION NO. NSH-0656-2020 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that the Memorandum of Agreement dated March 3, 2020 made and executed by and among the National Housing Authority (NHA), Bilrey Construction , and Kristoffee Heights Homeowners Association, Inc. for the acquisition of 1,412 developed lots and completed housing units in Kristoffee Heights , a socialized housing project of the NHA under its Community-Based Initiative Approach intended for the qualified beneficiaries of informal settler families affected by the 8.2 Segment Project of the Department of Public Works and Highways, located at Brgy. Calubcob, Naic, Cavite, to be undertaken by Bilrey Construction , is not subject to capital gains tax (CGT)/income tax/creditable withholding tax (CWT), documentary stamp tax (DST) and value-added tax (VAT) pursuant to Sections 19 and 20 of Republic Act (RA) No. 7279 and Section 109 (1) (P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Moreover, the Unilateral Deed of Absolute Sale executed by the Landowners in favor of the NHA over the parcel of land described below, to wit: Date Name of Landowners Transfer Certificate of Title (TCT) No. Area (Sq. m.) Area Transferred (Sq. m.) Location Oct. 05, 2020 1. Fiorello R. Estuar, married to Flor L. Estuar; 2. Mila R. Estuar; and 3. Edita R. Estuar. _____ _____ _____ Brgy. Calubcob, Naic, Cavite which shall be used for the above-mentioned socialized housing project is not subject to CGT/income tax/CWT, DST and VAT pursuant to Sections 19 and 20 of RA No. 7279 and Section 109 (1) (P) of the Tax Code of 1997, as amended. Furthermore, the Deeds of Absolute Sale (DOAS) executed by and between the Landowners and Bilrey Construction over the parcels of land described below, to wit: Date Name of Landowners Transfer Certificate of Title (TCT) Nos. Area (Sq. m.) Area Transferred (Sq. m.) Location Aug. 25, 2020 Loida I. Viado, married to Emiliano Viado, Jr. _____ _____ _____ Brgy. Calubcob, Naic, Cavite Aug. 25, 2020 Luis V. Novero, married to Rosario Novero _____ _____ _____ Brgy. Calubcob, Naic, Cavite which shall also be used for the above-mentioned socialized housing project is not subject to CGT/income tax/CWT , and VAT pursuant to Section 20 of Republic Act (RA) No. 7279 and Section 109 (1) (P) of the Tax Code of 1997, as amended. However, such DOAS are subject to DST imposed under Section 196 of the Tax Code of 1997, as amended, based on the consideration contracted to be paid for such realties or on their fair market value determined in accordance with Section 6 (E) of the same Code, whichever is higher. 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, 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 application for exemption, a lien on the titles of the land shall be annotated by the concerned RD having jurisdiction over the property, 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 2nd day of December, 2020. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue