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NC Rodriguez Construction

Certificate of Tax Exemption No. NSH-370-2022 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Aug 22, 2022

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August 22, 2022 CERTIFICATE OF TAX EXEMPTION NO. NSH-370-2022 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that NC RODRIGUEZ CONSTRUCTION , an entity engaged by the Municipal Government of Abulug, Cagayan , 1 is exempt from project-related income taxes and creditable withholding tax pursuant to Section 20 (d) (1) of Republic Act (RA) 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 house construction of 58 socialized housing units in Abulug Resettlement Project located at Brgy. Dana-ili, Abulug, Cagayan, intended for the calamity victims of Abulug and will be used as a relocation site for the qualified beneficiaries. Moreover, the delivery of 58 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 2 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 3 with selling price of not more than P3,199,200.00. However, the purchases of goods/articles by NC RODRIGUEZ CONSTRUCTION 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 NC RODRIGUEZ CONSTRUCTION must issue VAT-exempt official receipts on its gross receipts from the said socialized housing project. Moreover, the Deeds executed by the Landowners in favor of the Local Government Unit of Abulug, Cagayan over the parcels of land described below, to wit: Deeds Date Name of Landowners/ Sellers Transfer Certificate of Title No. Area (Sq.m.) Area Transferred (Sq.m.) Location Extra-Judicial Settlement of Estate and Deed of Absolute Sale July 5, 2020 AAA BBB CCC 4 T-5556 4,871 4,871 Brgy. Dana-ili, Abulug, Cagayan Extra-Judicial Settlement of Estate and Deed of Absolute Sale and Affidavit of Non-Tenancy November 5, 2020 DDD EEE FFF GGG 5 T-1346 10,653 5,129 Brgy. Dana-ili, Abulug, Cagayan which shall be used for the above-mentioned socialized housing project is not subject to capital gains tax pursuant to Section 20 (d) (2) of Republic Act (RA) No. 7279, as amended by RA No. 10884 (Balanced Housing Development Program Amendments) dated July 17, 2016. The transaction is, however, subject to documentary stamp tax under Section 196 of the National Internal Revenue Code of 1997, as amended, based on the actual consideration of the property transferred considering that one of the parties is the Government. 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 of the Municipal Government of Abulug, Cagayan 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 22nd day of August, 2022. (SGD.) LILIA CATRIS GUILLERMO Commissioner of Internal Revenue Footnotes 1. Per Contract Agreement dated July 8, 2021. 2. As adjusted using the 2010 Consumer Price Index values per Revenue Regulations No. 8-2021 dated June 11, 2021. 3. Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 4. This Certificate of Tax Exemption does not include exemption from estate tax on the transfer of TCT No. T-5556 from its registered owner, HHH, to his heirs. 5. This Certificate of Tax Exemption does not include exemption from estate tax on the transfer of TCT No. TC-1346 from its registered owners, III and JJJ, to their heirs.

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