BIR Ruling No. 43-2020

BUREAU OF INTERNAL REVENUE REPUBLICOF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: BOILEH-009-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

income received directly in connection with its economic and low-cost housing project, Phirst Park Homes Lipa Phase 1A, consisting of 470 house and lot units used solely for family home or dwelling purposes, located at Brgy. San Lucas, Lipa City, Batangas, a project duly registered a period of 4 years beginning from July 11, 2018 to July 10, 2022, pursuant to Executive Order No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 Number with the Board of Investments (BOI) under Registration No. (B)(2) of Revenue Regulations No. 2-98, as amended. This certifies that PHIRST PARK HOMES INC., with Taxpayer Identification , is exempt from income tax and creditable withholding tax on its dated July 11, 2018, for

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

by this Certificate of Tax Exemption and shall be subject to applicable taxes under the 1997 units used for commercial purposes such as leasing, retail stores, offices, etc., are not covered The sale of house and lot units in excess of the 470 house and lot units, including those

Tax Code, as amended.

applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof. The grant of tax exemption herein is subject to the compliance with the provisions of

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 ofJAN 1 0 2020

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CAESAR R.DULAY Commissioner of Internal Revenue K-1-JAC 031958

1

Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963

Phirst Park Homes Inc. -- Phirst Park Homes Lipa Phase IA Page 2of 2 CTENO.BOI-LEH-0092020 Date issued JAM 1 0 2021

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, Phirst Park Homes Lipa Phase 1A consisting of 470 house and lot units, located at Brgy. San Lucas, Lipa City, Batangas. Such exemption shall not cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the 470 house and lot units per HLURB License to Sell No. shall not be sold

for more than P1,700,000.00 per house & lot.

2.The enterprise shall observe the following project timetable

Activity Period

Land acquisition December 2017 - May 2019

Secure necessary license/permit/registration from the government/training costs January 2018 - May 2018

Site preparation and development January 2018 - September 2018

Building/House construction January 2018 - May 2018

Start of Commercial Operations July 2018

3.In the computation of the project's ITH, the following shall apply:

a. Only income generated from the sale of house and lot units (Phirst Park Homes Lipa Phase 1A, Brgy. San Lucas, Lipa City, Batangas) with selling price not exceeding

PhP2.OM and used solely for family home or dwelling purposes and not for commercial

purposes such as leasing, retail stores, offices, etc. shall be.qualified.

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

from the registered activity.

4 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

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 thirty (30) days from the deadline for filing of tax returns and

payment of taxes.

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 Tax Code of

1997, as amended and implemented by Revenue Regulations (RR) No. 2-98, as amended.

6.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 Tax Code

of 1997, as amended.

An ActEnhancing Transparency in the Management and Accounting of Tax Incentives Administeredby vestment Promotion Agence