BIR Ruling No. 347-2020

BUREAU OFINTERNAL REVENUE REPUBLIC OFTHE PHILIPPINES DEPARTMENT OF FINANCE

Certificate of Tax Exemption No: P01-1aH -03 4 7-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

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 for family home or dwelling purposes, located at Brgys. Navarro, Pasong Camachile and June 2013 or actual start of commercial operations/selling, whichever is earlier, but in no case (B)(2) of Revenue Regulations No. 2-98, as amended. Bacao, General Trias, Cavite, a project duly registered with the Board of Investments (BOI) withholding tax on its income received directly in connection with its low-cost housing project (horizontal), KENSINGTON PHASE 17, consisting of 1,084 house and lot units used solely under Registration No. IdentificationNumber This certifies that PROPERTY COMPANY OF FRIENDS, INC., with Tax dated June 27, 2013, for a period of 3 years beginning from is exempt from income tax and creditable

below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is VAT-exempt under Section 109(1)(P) of the 1997 Tax Code, as amended. Provided, however. that beginning January 1, 2021, the VAT exemption shall apply only to sale of house and lot and other residential dwellings' with selling price of not more than Two Million Pesos (P2,000,000.00). Moreover, the sale by the Company of residential lots valued at P1,919,500.00 and

for commercial purposes such as leasing, retail stores, offices, etc., shall be subject to the applicable taxes under the 1997 Tax Code, as amended. to Sell No. The sale, however, of housing units in excess of the 1,084 units (per HLURB License , the excess is 16 units) registered with the BOI, including those units used

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 ofJUN 2 5 2020

We3ady

K Commissioner of Internal Revenue CAESAR R.DULAY 935550

Sale of lot only regardess of the pricshalbe subject toVAT starting Janary 1.2021 pursuant to RANo.10963.

Property Company of Friends, Inc. CTE No.1O(-LH 3 4 7.2 3 2 s

Page 2 of 2 Date issued jUN 2 5 2n20

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

1. The exemption from income and creditable withholding taxes covers only income directly

attributable to the revenues generated from the project, KENSINGTON PHASE 17

consisting of 1,084 house and lot units located at Brgys. Navarro, Pasong Camachile and Bacao, General Trias, Cavite. Such exemption shall not cover revenues from units with Selling price exceeding P3,000,000.00. Moreover, the housing units shall not be sold for a price exceeding P1,250,000.00 based on HLURB License to Sell No.28981.

2. The Company is obligated to construct and sell 1,084 housing units based on the following

schedules/sales revenues:

Year (No. of Units) Volume Value (PhP)

2 3 434 325 325 344,500,000 460,040,000 344,500,000

Total 1,084 1,149,040,000

3. In the computation 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. 107082, the Company is required to file its tax

returns and pay its tax liabilities, on or before the deadline as provided under the 1997 Tax

Code, as amended, using the electronic 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 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. shall file with BOI a complete annual tax incentives report of its income-based tax incentives,

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

withhoiding taxes as source as required under Chapter XIlI 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 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 Companys 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 anypursuant to Section 235 of the Tax Code

of 1997, as amended.

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

Promotion Agencies.