June 25, 2010
BIR RULING [DA-(C-026) 111-10]
RA 8763; BIR Ruling 002-03; DA-400-2003
Mariza M. Rabago-Uy
OIC-Revenue District Office
RDO No. 53-A, Las Piñas City
Madam :
This refers to your Memorandum dated February 25, 2010 requesting for legal opinion as to the taxability of the sale of property by HomeCredit Mutual and Loan Association (HomeCredit).
It appears that HomeCredit is a domestic mutual building and loan association duly organized and existing under the laws of the Philippines; that HomeCredit has been operating as a mutual benefit building and loan association whereby its stockholder-members contribute to the capital build-up of the association by way of subscription or fixed dues (regular, equal and periodical payments); that the Bureau previously issued BIR Ruling No. 002-03 dated February 12, 2003 and DA-400-2003 dated November 6, 2003, wherein it was confirmed that HomeCredit, as a building and loan association guaranteed by the Home Guaranty Corporation, is exempt from all taxes; and that HomeCredit sold a parcel of land situated at Barangay Almanza Doz, Las Piñas, Metro Manila and covered by TCT No. T-112578 to Abigail Joy...
