Title
Supreme Court
CAR/TCL Issuance for Condo Corp Land Transfer
Law
Bir Revenue Memorandum Order No. 18-2009
Decision Date
Apr 26, 2009
BIR Revenue Memorandum Order No. 18-2009 streamlines the process for real estate developers to transfer land and common areas to Condominium Corporations by eliminating the requirement for a prior Bureau of Internal Revenue ruling, thereby expediting the issuance of Certificates Authorizing Registration and Tax Clearances.

Law Summary

Objectives

  • Streamline and expedite the issuance process of CAR/TCL for such transfers.
  • Establish clear guidelines and procedures for issuance.

Dispensing with Prior BIR Ruling Requirement

  • The BIR removes the need for securing a prior ruling before issuing CAR/TCL for transfers to Condominium Corporations under RA 4726.
  • Taxpayers may still opt to obtain a ruling for confirmation.
  • The Revenue District Officer (RDO) may issue CAR/TCL upon verifying documents and ensuring the transfer's facts align with precedent rulings.

Key Factual Requirements for Transfer

  • The real estate developer is registered owner of the land with condominium development under RA 4726.
  • A Condominium Corporation is duly formed to hold and manage the land and common areas solely for the benefit of unit owners.
  • Corporation's articles/by-laws comply with RA 4726 and related instruments.
  • Membership in the corporation is appurtenant to unit ownership and not separately transferable.
  • The corporation cannot transact properties for profit.
  • A Deed of Conveyance, free of liens/encumbrances, transfers title from developer to corporation without monetary consideration.

Documentary Requirements for CAR/TCL Issuance

  • Letter request signed by authorized representative stating reasons and facts justifying the transfer.
  • Certified true copies of notarized Master Deed of Conveyance with Declaration of Restrictions, any amendments thereto.
  • Certified true copies of Transfer Certificate of Title (TCT), tax declarations for land and common areas.
  • Certified true copies of SEC Registration, Articles of Incorporation, and by-laws of the Condominium Corporation.

Tax Implications of the Transfer

  • No taxable income or creditable withholding tax arises since the conveyance is without consideration and not a sale.
  • Exempt from Documentary Stamp Tax (DST) on the deed pursuant to relevant regulations, except for a fixed DST of P15.00 on the notarial acknowledgment.
  • Transfer is not subject to VAT, as beneficial ownership remains effectively with original party; no monetary consideration is paid.

Repealing Clause

  • All inconsistent issuances or provisions are repealed or amended accordingly.

Effectivity

  • The Order is effective immediately upon issuance.

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