Raemulan Lands, Inc.
Certificate of Tax Exemption No. PSH-255-2022 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • May 27, 2022
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May 27, 2022 CERTIFICATE OF TAX EXEMPTION NO. PSH-255-2022 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that RAEMULAN LANDS, INC. , with Taxpayer Identification Number 000-000-000-000, 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 sale of socialized house and lot units for residential and dwelling purposes to qualified beneficiaries in Pasinaya Homes Prime South , consisting of 1,806 house and lot units located at Brgy. Timalan Balsahan, Naic, Cavite , a project duly registered with the Department of Human Settlements and Urban Development (DHSUD) under Provisional Certificate of Registration No. 525 and Provisional License to Sell No. 686 both dated April 04, 2022, provided that the selling price of said house and lot units does not exceed P580,000.00 per house and lot packages. 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 1 with selling price of not more than P3,199,200.00. 2 Furthermore, the Deeds of Absolute Sale executed by the Landowners in favor of RAEMULAN LANDS, INC. over the parcels of land described below, to wit: Date Name of Landowners Transfer Certificate of Title (TCT) Nos. Area (sq. m.) Transferred (sq. m.) Location Dec. 03, 2018 AAA married to BBB 809197 3 36,647 36,647 Naic, Cavite Dec. 03, 2018 CCC married to DDD 057-2017061394 4 42,972 42,972 Dec. 03, 2018 CCC married to DDD 057-2017061392 5 76,813 76,813 Dec. 03, 2018 EEE 057-2021041430 23,009 23,009 Dec. 03, 2018 FFF married to GGG 057-2014048565 6 10,142 10,142 Dec. 03, 2018 FFF married to GGG 057-2018027968 7 16,452 16,452 Dec. 03, 2018 HHH married to III T-809187 8 12,496 12,496 Dec. 03, 2018 FFF married to GGG 057-2020028518 9 23,323 23,323 Total 241,854 241,854 which shall be used for the abovementioned socialized housing project are not subject to capital gains tax (CGT) pursuant to Section 20 (d) (2) of RA No. 7279, as amended, and to VAT pursuant to Section 109 (1) (P) of the Tax Code of 1997, as amended. 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 hereof. The Company is liable, however, for all other applicable taxes not enumerated 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. Issued this 27th day of May, 2022. CAESAR R. DULAY Commissioner of Internal Revenue By: (SGD.) MARISSA O. CABREROS Deputy Commissioner Legal Group Officer-in-Charge ATTACHMENT TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION 1. The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, Pasinaya Homes Prime South consisting of 1,806 house and lot units, located at Brgy. Timalan Balsahan, Naic, Cavite . Such exemption shall cover revenues from 1,806 house and lot units with selling price not exceeding P580,000.00 per house and lot packages. 2. The developer shall submit the sworn statement of the buyer that he is eligible as a socialized housing beneficiary provided under Section 5 (A) of Revenue Regulations (RR) No. 11-97 to the Bureau of Internal Revenue (BIR) during the processing of the Certificate Authorizing Registration (CAR) for the transfer of the socialized housing unit. 3. It is understood that the CAR shall only be issued after it is established upon proper verification by the Revenue District Officer (RDO) concerned that, considering the rules on valuation of real property, the actual selling price per sale transaction of the house and lot packages in this case does not really exceed P580,000.00. Footnotes 1. Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 2. As adjusted using the 2010 Consumer Price Index values pursuant to Revenue Regulations (RR) No. 8-2021 dated June 11, 2021. 3. Already in the name of Raemulan Lands, Inc. under TCT No. 057-2021016255. 4. Already in the name of Raemulan Lands, Inc. under TCT No. 057-2021016235. 5. Already in the name of Raemulan Lands, Inc. under TCT No. 057-2021030220. 6. Already in the name of Raemulan Lands, Inc. under TCT No. 057-2021016258. 7. Already in the name of Raemulan Lands, Inc. under TCT No. 057-2021016259. 8. Already in the name of Raemulan Lands, Inc. under TCT No. 057-2022010244. 9. Already in the name of Raemulan Lands, Inc. under TCT No. 057-2021049428.
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