BIR Ruling No. 676-2017

BUREAU OF INTERNAL REVENUE REPUBLIC OF THB PHILIPPINES DEPARTN NT OF FINANCE

Quezon City

Certificate of Tax Exemption No: #676-2017 12/29/2017

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

No. tax (CWT) and value-added tax (VAT) pursuant to Section 20 of Repubiic Act (RA) No. 7279 on its income received directly in connection with its sale of socialized housing units to Looc, Calamba, Laguna, a project duly registered with the Housing and Land Use Regulatory Identification Number qualified beneficiaries in Centennial De Calamba, consisting of 671 units, located at Brgy. Board (HLURB) under Certificate of Registration No. exceed This certifies that CUMBERLAND DEVELOPMENT CORPORATION, with Tax and , provided that the ceiling price per house and lot package does not for lot only. is exempt from income tax, creditable withholding nd License to Sell

higher. 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 market value determined in accordance with Section 6 (E) of the same Code, whichever is 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 Nonetheless, it is observed that documentary stamp tax (DST) is not one of the taxes

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 DEC 2 9 2017

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Commissioner of Internal Revenue CAESAR R. DULAY 012185 K-Y-JAC

1 The maximum selling price is pegged at 300,000.00 based on HLURB License to Sell No.

Page 2 of 2 Cumberiand Development Corporation/Centennial De Cadamba CTE No.676-2017 Date issued 12/29/2017

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption from income, creditable withholding taxes and VAT covers only income directly attributable to the revenues generated from the 671 socialized housing units in Centennial De Calamba, located at Brgv. Looc. Calamba, Laguna.

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 oniy be issued concerned that, considering the rules on valuation of real property, the actual selling after it is established upon proper verification by the Revenue District Officer (RDO) price per sale transaction of the socialized house and lot packages in this case does not really exceed P300,000.00 and P120,000.00 for lot only.

4 List of Non-saleable lots per HLURB License to Sell No , granted

by the HLURB, Region VI-A, Quezon City, to wit:

Block 1 -- Parking Area

Block 7 -- Lot 28 - Community Facilities

Block 12 -- Lot 20 - Community Facilities

Block 12 -- Lot 19 - Parks/Playgrounds Block 16 -- Lot 4 - Parks/Playgrounds Block 26 -- Lot 12 - Parks/Playgrounds Block 30 -- Lot 14 - Parks/Playgrounds Block 30 -- Lot 13 - Reserved Area