BIR Ruling No. 272-2020

REPUBLIC OF THE PHILIPPINES

BUREAUOF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No:

BOI-LEH-0272-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

Novaliches,Quezon City, consisting of 814 housing units used solely for family home or dwelling purpose,located at Brgy.San Barolme,NovalicheQuezon Citya prject duly withholding tax on its income received directly in connection with its economic and low-cost housing project (vertical),Vine Residences Phase ITowers 12Brgy.San Bartolome 13,2017, for a period of three 3years beginning from December 2017 or actual start of commercial operations/selling, whichever is earlier, but in no case earlier than the date of registration of the project with the BOI, pursuant to Executive Order (EO) No. 226, 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. Identification Number (TIN registered with the Board of Investments (BOI) under Registration No. This certifies that SM DEVELOPMENT CORPORATION, with Taxpayers is exempt from income tax and creditable dated January

below, or 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 exemption from VAT shall only apply to sale of house and lot and other residential dwellings Revenue Code of 1997, as amended. Provided, however, that beginning January 01, 2021, the 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

purposes such as leasing, retail stores, offices, etc.,shall be subject to the payment of appropriate taxes under the National Internal Revenue Code of 1997, as amended. the BOI, if any, as well as the 315 parking slots, including those other units used for commercial However, the sale of housing units in excess of the 814 housing units registered with

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 of . MAY 2 6 2020

iasara

K-1-LMAT Commissioner of Internal Revenue CAESAR R.DULAY 035088

Sale of lot only, regardless of the price, shall be subject to VAT starting January O1, 2021 pursuant to Republic Act (RA) No. 10963.

SM DEVELOPMENT CORPORATION (Vine Residences Phase I(Towers 1 &2)] CTE NO.: BOL-LEH-0272-20 20

Date issued: MAY 2 5 2020

1 The exemption from income and creditable withholding taxes covers only income directly OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

2 The Company is obligated to construct and sell 814 housing units based on the following attriutable to the revenues generated frm the projectVine ReidencePhae I Tower I2) family home or dwelling purpoe, located at BrgySan Bartolome,Novaliche,Queon City.Such exemption shall not cover revenues from units with selling price exceeding P3,000,000.00. -BrgySan BartolomeNovalichesQuezon City,consiting of14 using units ued soely for

schedules/sales revenues:

Year 2 1 (No. of Units Volume 495 124 195 1,172,709 (PhP'000) 293,770 461,976 Value

3

3: 4 In the computation of the project's ITH, interest income from in-house financing shall not be The-Company's-entitlement-to -ITH-for~its -BOI-registered housing project is-subject to- the considered as part of the revenues generated from the registered housing project. Total 814 1,928,455

5 Pursuant to Section 4 of Republic Act (RA) No. 107082, the Company is required to file its tax compliance with the provisions of the Specific Terms and Conditions of its BOI Registration.

7.The Company is required to file on or before the 15t day of the fourth month following the close 6 The Company shall be constituted'as a withholding agent for the government if it acts as employer of its accounting period of a Profit and Loss Statement and Balance Sheet with the Annual be provided under E.O.226, within the periods prescribed under RA No.10708's Implementing 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. Information Return under oath, stating its gross income and expenses incurred during the taxable Rules and'Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. year. 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 returns and pay its tax liabilities, on or before the deadline as provided under the National Internal

8. Finally, the Company's books of accounts and other pertinent records shall be subject to periodic 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, examination by revenue enforcement officers of this Bureau for the purpose of ascertaining whether as amended.

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

PAGE 2OF2