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April 16, 2010BIR RULING [DA-(VAT-009) 050-10]109 (P); Sec. 4.109-1 (B) (p), RR 16-2005; DA-(VAT-011) 270-08Paco Catholic School 1521 Paz Street, Paco,ManilaAttention: Msgr. Domingo A. Cirilos, Jr.School Director Gentlemen :This refers to your letter requesting, in effect, for exemption from the payment of value-added tax (VAT) on the sales by Paco Catholic School ("PCS" for brevity) of residential condominium units for a consideration less than the threshold amount as provided for under Section 109 (P) of the Tax Code of 1997, as amended. It is represented that the PCS, a non-stock, non-profit educational institution owned and operated by the Roman Catholic Archdiocese of Manila (RCAM), has been granted by the Housing and Land Use Regulatory Board (HLURB) a Development Permit on July 10, 2007, to build an Eleven (11) Storey PCS Residences, a condominium project for the employees of PCS; that the said condominium project is located at 1285 Calixto Dyco Street, Lucban, Paco, Manila; that the HLURB has certified the same to be a socialized housing project; that the said housing project has been conceived...