BIR Ruling No. 606-2017

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificato of Tax Exemption No: 603-2017

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

DEVELOPMENT CORPORATION, with Tax Identification Number ThiscertifiesthatSR.STO. NINODECEBU RESOURCES AND IS exempt from income tax and creditable withholding tax on its income received directly in connection with its cconomic and low-cost housing project, Avant Garde Residences, Batches II and III, consisting of 186 units located at Brgy. San Roque, Sto. Tomas. Batangas. a project duly registered with the Board of Investments (BOI) under Registration No.

dated April 25, 2017, for a period of 3 years beginning from April 2017 or actual start of commercial operations/selling. whichever is carlicr, but in no case earlier than the date of registration of thc project with the BO1, pursuant to Executive Order No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations No. 2-98. as amended.

below. or house and lot and other residential dwellings valued at P3, 199.200.00 and beiow. is Moreover, the sale by the Company of residential lots valued at P1.919.500.00 and

VAT-exempt under Section 109(1)(P) of the 1997 Tax Code, as amended.

The sale, however. of housing units in excess of the 186 units registered with BOI shall be subject to the regular taxes as may be applicable.

The grant of tax exemption herein is subject to the compliance with the provisions of

The Company is liable, however. for ali other applicable taxes not discussed above. applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof.

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. This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this. day of DFC_1 4_2017

K - Commissioner of Internat Revenue CAESAR R. DULA *011710

Sr. Sto. Nifo De Cebu Resources & Dev't. Corp. Page 2 of 2 Date issued 12-L -20 1? CtE No. 606-2017

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1 The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, Avant Garde Residences Batches II and III, consisting of 186 units located at Brgy. San Roque. Sto. Tomas. Batangas. Such exemption shalt not cover revenues from units with selling price exceeding P3.000.000.00.

2. The Company is obligated to construct and sell 186 housing units based on the following schedules/sales revenues:

Tota Y ear 1 3 (No. of Units) Volume 186 12 62 6 Value(Php 000)

3. In the computation of the project's I'TH, interest income from in-house financing shall not be considered as part of the revenues generated from the registered housing project.

4 Thc Company's entitlement to ITH for its BOI-registered housing project is suhject to the compliance with the provisions of the Specific Terms and Conditions of its BOi Registration.

5 Pursuant to Section 4 of Republic Act (RA) No. 10708', the Company is required to file its tax shall file with BOI a complete annual tax incentives report of its income-based tax incentives. provided under E.O. 226. within the periods prescribed under R.A. 10708's Implementing Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1. 2016. returns and pay its tax liabilities, on or before the deadline as provided under the 1997 Tax Code, as amended, using the etectronic system for filing and payment of taxes of the BIR. It VAT and duty exemptions, deductions, credits or exclusions from the tax base. as may be

6 The Company shall be constituted as a withholding agent for the government if it acts as employer and any of its employees received compensation income subject to compensation withhoiding tax. or if it makes payments to individuals or corporations subject to the withholding taxes as source as required under Chapter XHII and Section 57 of the Tax Code of 1997, as amended and implemented by Revenue Regulations (RR) No. 2-98, as amended. 7. The Company is required to file on or before the 15t" day of the fourth month folfowing the close of its accounting period of a Profit and Loss Statement and Balance Shect with the Annual Information Return under oath. stating its gross income and expenses incurred during the taxable year.

8. Finally, the Company's books of accounts and other pcrtinent records shall be subject to periodic examination by revenue enforcement officers of this Bureau for thc purpose of ascertaining whether it is complying with the conditions under which it has been granted tax exemption or tax incentives and its tax liability, if any. pursuant to Section 235 of the Tax Code of 1997, as amended.

Investment Promotion Agencies. An Act Enhancing 'T'ransparency in the Management and Accounting of Tax Incentives Administered by