BIR Ruling No. 656-2017

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: 556*2017

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

tax (CWT) and vaiue-added tax (VAT) pursuant to Section 20 of Republic Act (RA) No. 7279 Identification Number This certifies that BORLAND DEVELOPMENT CORPORATION, with Tax is exempt from income tax, creditable withholding

on its income received directly in connection with its sale of socialized housing units to qualified beneficiaries in Azalea Homes, consisting of 911 units, located at Brgy. Sapang Maisac, Mexico Pampanga, a project duly registered with the Housing and Land Use Regulatory Board (HLURB) under Certificate of Registration No. and License to Sell No P450,000.00 for house and lot and P180,000.00 for lots only. , provided that the ceiling price per house and lot package does not exceed

Nonetheless, it is observed that documentary stamp tax (DST) is not one of the taxes covered by the tax exemption clause in Section 20 of RA No. 7279. Such being the case. the owner/project developer/seller shall be liable to pay the documentary stamp tax on the documents conveying the properties imposed under Section 196 of the Tax Code of 1997, as amended. based on the consideration contracted to be paid for such realties or on their fair market value determined in accordance with Section 6 (E) of the same Code. whichcver is higher. Likewise. lots/units classified as Economic Housing. not being covered by R.A. No. 7279. shall be subject to the payment of appropriate taxes.

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

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

Issued this.. day of0EC1 9 2017

QCM

CAESAR R. DULAY Commissioner of Internal Revenue 011945

K-1-JAC

Borland Devetopment Corporation/Azalea Homes Page 2 of 2 CTE No. Date issued 1:-19-20:7 656-017

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

t. The exemption from income, creditable withholding taxes and VAl covers only units in Azalea Homes, located at Brgy. Sapang Maisac, Mexico, Pampanga income directly attributable to the revenues generated from the 911' socialized housing

2. The developer shall submit the sworn statement of the buyer that he is eligible as a socialized housing beneficiary under Section 5 (A) of Revenue Regulations (RR) No. 11-97 to the BIR during the processing of the Certificate Authorizing Registration (CAR) for the transfer of the title of the socialized housing unit.

3 It is understood that the Certificate Authorizing Registration (CAR) shall only be issued after it is established upon proper verification by the Revenue District Officer (RDO) concerned that. considering the rules on valuation of real property, the actual selling price per sale transaction of the socialized house and lot packages in this case does not really exceed P450.000.00 and P180.000.00 for lot only.

4. List of Socialized Housing Units which are credited to its Main Project. Azalea Homes. located at Brgy. Sapang Maisac, Mexico, Pampanga per HLURB License to Sell No.

03 1850 granted by the HLURB, Region III, San Fernando City. Pampanga to wit:

Azalea Homes Block No. Lot Nos. No. of Lots

L 4 2 3 1 3-26, 31-60 3-26, 31-60 3-26, 31-60 3-26, 31-60 3-26, 31-54 3-26, 3 1-58 3-26, 31-60 52 54 54 5 54 48

TO 8 O 3-26, 3 1-60. 62 3-26, 31 -60, 62 3-26, 31-60, 62 3-26, 31-61 S 55 55 55

20 17 1 1 1 9 I 2 13 14 1.3-15, 19-25. 27, 29-3 2, 3, 4, 5. 7-13, 15, 18 3-26, 31-60, 62 3-26, 31-60, 62 3-26, 31-60, 62 20-27, 29, 30 3-26, 31-59 3-26, 31-59 Tota! 2 1 2 23 5' 53 3 5 5

1 The maximurm selling price is pegged at 450,000.00 based on HLURB License to Selt No