BIR Ruling No. 661-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE Quezon City

Certificate of Tax Exemption No:

BOI-LEH-0661-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

Revenue Regulations (RR) No. 2-98, as amended, provided that the selling price of said residential tax on its income received directiy in connection with its economic and low-cost housing project, Urban of 3,264' residential units used solely for family home or dwelling purposes, located at Sitio Orel, Brgy. Certificate of Registration No. in no case earlier than the date of registration of the project with the BOI, pursuant to Executive Order No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B) (2) of units does not exceed P2,000,000.00 per residential unit. Deca Homes Banilad -- Tower 1, 2 & 3 -- Sitio Orel, Brgy. Banilad, Mandaue City, Cebu, consisting Banilad, Mandaue City, Cebu, a project duly registered with the Board of Investments (BOI) under beginning from August 2020 or actual start of commercial operations/selling, whichever is earlier, but Identification Number (TIN) This certifies that 8990 HOUSING DEVELOPMENT CORPORATION,with Taxpayer dated August 24, 2020, for a period of four (4) years is exempt from income tax and creditable withholding

house and lot and other residential dwellings valued at P3,199,200.00 and below, is exempt from value- added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code of 1997, as amended. Provided, however, that beginning January 01, 2021, the exemption from VAT shall only apply to sale of house and lot and other residential dwellings2 with selling price of not more than P2,000,000.00. Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and below, or

National Internal Revenue Code of 1997, as amended. BOI, if any, including the 545 shared parking slots and those units used for commercial purposes such as leasing,- retail stores, offices, etc., shall be subject to the payment of appropriate taxes under the However, the sale of residential units in excess of the 3,264 residential units registered with the

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 applicable

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 documents as

Issued this day of DEC 1-7 2020

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K-1-MDT Commissioner of Internal Revenue CAESAR R. DULAY 03865

2 Sale of lot only, regardless of the price, shall be subject to VAT.starting January 01, 2021 pursuant to RA No..10963. 1 Covered by the following Provisional Certificates of Registration (PCOR) and Provisional Licenses to Sell (PLTS) issued by the Housing and Land Use Regulatory Board (HLURB): PCOR No. PCOR No PCOR No. and PLTS Nc and PLTS No. and PLTS No. Total Tower 1 Tower 2 Tower 3 1,156 units 1,156 units 3,264 units 952 units

(Urban Deca Homes Banilad -- Tower 1, 2 & 3) 8990 HOUSING DEVELOPMENT CORPORATION Date issued: CTE No.: BOI-LEH-0661-2020

SOF 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, Urban Deca Homes Banilad -- Tower 1, 2 & 3 -- Sitio Orel, Brgy. Banilad, Mandaue City, Cebu, consisting of 3,264 residential units used solely for family home or dwelling purposes, located at Sitio Orel, Brgy. Banilad, Mandaue City, Cebu. Such exemption shall not cover revenues from units with selling price exceeding P2,000,000.00.

2.In the computation of the project's ITH, the followingshall apply:

a Only income generated from the sale of housing units (Urban Deca Homes Banilad --

commercial purposes such as leasing, retail stores, offices, etc. shall be qualified. exceeding Php2.0M and used solely for family home or dwellingpurposes and not for Tower 1, 2 & 3 - Sitio Orel, Brgy. Banilad, Mandaue City, Cebu)|with selling price not

b. Interest income from in-house financing shall not be. considered as revenues generated

from the registered activity.

3. The Company's entitlement to ITH for its BOI-registered housingproject is subject to the

compliance with the provisions of the Specific Terms and Conditions of its BOI Registration.

4.Pursuant to Section 4 of Republic Act (RA) No. 107083, the Company is required to file its tax

returns and pay its tax liabilities, on or before the deadline as provided under the National Internal

Revenue 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 E.O. 226, within the periods prescribed under RA No. 10708's Implementing Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016.

5. 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 individuals or corporations subject to the withholding taxes as source as

required under Chapter XIII and Section 57 of the National Internal Revenue Code of 1997, as

amended, and implemented by Revenue Regulations (RR) No..2-98, as amended.

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.

7. Finally, the Company's books of accounts and other pertinent records shall be subject 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 National Internal Revenue Code of 1997.

as amended.

3 An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by Investment

Promotion Agencies.

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