BIR Ruling No. 264-2022

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Ii Certificate of Tax Exemption No:

BOJ-LE+-2 5 4 - 707

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

housing project, Lumina Tuguegarao Phase 1 and Phase 1 Classic - Brgy. Caraig, the date of registration of the project with the BOI, pursuant to Executive Order (EO) No. 226, reoistered with the Board of Investments (BOI) under Certificate of Registration No. actual start of commercial operations/selling, whichever is earlier, but in no case earlier than otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98, as amended. withholding tax on its income received directly in connection with its economic and low-cost Tuguegarao City, Cagayan consisting of 803 house and lot units used solely for family home or dwelling purposes, located at Brgy. Caraig, Tuguegarao City, Cagayan, a project dulv Identification Number (TIN) dated December 21, 2021, for a period of 4 years beginning from December 2021 or This certifies that PRIMA CASA I.AND & HOUSES, INCl. with Taxpayer is exempt from income tax and creditable

shall only apply to sale of house 'and lot"and other residential dwellings2 valued at below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is VAT-exempt under Section 109(1)(P) of the National Interral Revenue Code (Tax Code) of P3,199,200.003. 1997, as amended. Provided, however, that beginning January 01, 2021, the VAT exemption Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

registered with the BOI, if any, including those units used for commercial purposes such as leasing, retail stores, offices, etc. shall be subject to the payment of appropriate taxes under the Tax Code of 1997, as amended. However, the sale of house and lot units in excess of the 803 house and lot units

applicable BIR rules and regulations and the Terms and Conditions stated at the'back hereof. The Company is liable, however, for all other applicable taxes not discussed above. The grant of tax exemption herein is subject to the compliance with the provisions of

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 o MAY 2 7 2022

By: Commissioner of Internal Revenue CAESAR R. DULAY

3 As adjusted using the 2010 Consumer Price Index values pursuant to RR No. 8-2021 dated June 11, 2021. 2 Sale of lot only, regardiess of the price, shall be subject to VAT starting January 01, 202l.pursuant to RA No. 10963. K-1-MDT ' Formerly: Lumina Homes, Inc. MAriSSA Deputy Commissioner Offi&er-in-Charge Lega! Group o. cabreros 08.8.4

page 2 of 2 Lumina Tuguegarao Phase 1 and Phase 1 Classic Date issuedMAY_? T 2U2Z CTE No.E01-4H- 2 6 A - 2 3 :

OF THE CERTIFICATE OF TAX EXEMPTION FERMS AND CONDITIONS

The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, Lumina Tuguegarao Phase 1 and Phase shall not be sold for more than P solely for family home or dwelling purposes located at Brgy. Caraig, Tuguegarao Citv. Cagayan. Such exemption shall not cover revenues from units with selling price exceeding P. Moreover, the 803 house and lot units covered by Provisional License to Sell Nos. 1 Classic - Brgy. Caraig, Tuguegarao City, Cagayan, consisting of 803 house and lot units used Her house and lot. and

2. The enterprise shall observe the following project timetable:

Milestone Investment Cost and Schedule Site Preparation and Development Building/House Construction Start of Commercial Operations # Decamber 2019 - December 2025 February 2020 -- December 2025 December 202 1 Total Project Cost

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

4. The Company's entitlement to ITH for its BOI-registered housing project is subject 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. 107084, the Company is required to file its tax returns and pay its tax liabilities, on or before the deadline as provided under the Tax Code of 1997, as amended, using the electronic system for filing and payment of taxes of the BIR. It shall file with BOI a complete annual tax incentives report of its income-based tax incentives, VAT and duty exemptions, deductions, credits or exclusions from the tax base, as may be provided under EO No. Joint Memorandum Circular No. 1-2016 dated September I, 2016. 226, within the periods prescribed under RA No. 10708's Implementing Rules and Regulations and

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 withholding tax. or if it makes payments to inidividuals or corporations subject to the withholding taxes as source as required under Chapter XIII and Section 57 of the Tax Code of 1997, as amended, and implemented by RR No. 2-98, as amended.

7. The Company is required to file on or before the 15th day of the fourth month following the close of its accounting period of a Profit and Loss Statement and Balance Sheet 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 pertinent records shall be subiect to periodic examination by revenue enforcement officers of this Bureau for the 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.

An Act Enhancing Transparency in the Management and Accouriting of Tax Incentives Administered by Investment Promotion Agencies.

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