November 23, 2009
BIR RULING [SH-(115) 729-09]
20 RA 7279; DA-151-07
Urban Settlements Office
City of Manila
Room 569 5th Floor, Manila City Hall
Manila
Attention: Ms. Victoria S. Clavel
City Gov't Dept. Head III
Gentlemen :
This refers to your letter dated December 3, 2007 which was received by this Office by way of 2nd Indorsement dated January 24, 2008, Revenue Region No. 6, Manila requesting for exemption from the payment of project-related income taxes, capital gains tax/expanded withholding tax, value-added tax (VAT) and other taxes on the sale of parcels of land pursuant to Republic Act (R.A.) No. 7279, otherwise known as the "Urban Development and Housing Act of 1992".
Documents submitted disclosed that a Memorandum of Agreement was executed by the City of Manila and the Philippine National Railways ("PNR") stating that PNR is the owner of a prime property, popularly known as the Tutuban Mall which was being leased to Tutuban Properties, Inc.; that PNR had an outstanding obligation to the City of Manila representing unpaid realty taxes from 1992 up to 2001 which PNR had failed to settle; that the...
