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Rockwell Land Corporation

Certificate of Tax Exemption No. PSH-076-2022 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Feb 17, 2022

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February 17, 2022 CERTIFICATE OF TAX EXEMPTION NO. PSH-076-2022 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that ROCKWELL LAND CORPORATION 1 with Taxpayer Identification Number (TIN) ______________, is exempt from income tax and creditable withholding tax (CWT) 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 its sale of socialized house and lot units for residential and dwelling purposes to qualified beneficiaries in Stonewell Mahogany Homes , consisting of 443 house and lot units, located at Brgy. San Pedro, Sto. Tomas, Batangas, a project duly registered with the Housing and Land Use Regulatory Board (HLURB) under Certificate of Registration No. _________ and License to Sell No. __________ provided that the selling price of said units does not exceed P450,000.00 2 per house and lot. Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, 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 4 It is observed, however, that documentary stamp tax (DST) is not one of the taxes covered by the tax exemption clause in Section 20 of RA No. 7279. Thus, the documents conveying the properties shall be 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. Likewise, lots/units classified as Economic Housing, not being covered by RA No. 7279, shall be subject to the payment of appropriate taxes. The grant of tax exemption herein is subject to the compliance with the provisions of applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof. The Company is liable, however, for other applicable taxes not discussed above. This Certificate of Tax Exemption 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. IAETDc Issued this 17th day of February, 2022. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. Doing business under the name and style of Powerplant Mall; Powerplant Cinemas; and Edades Serviced Apartments. 2. Per HLURB License to Sell No. _____ dated September 21, 2018. 3. Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 4. As adjusted using the 2010 Consumer Price Index values per Revenue Regulations (RR) No. 8-2021 dated June 11, 2021.

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