BIR Ruling No. 268-2022

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax. tion No:

B0-lE:

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

tax on its income received directly in connection with its economic and low-cost housing Number (TIN) This certifies that COMMUNITIES PAMPANGA, INC. with Taxpayer Identification is exempt from income tax and creditable withholding

project, Bria Homes San Fernando -- Brgy. Calulut, City of San Fernando, Pampanga, consisting of 660 house and lot units used solely for family home or dwelling purposes, located at Brgy. Calulut, City of San Fernando, Pampanga, a project duly registered with the Board of Investments (BOI) under Certificate of Registration No. dated December 23, 2021, for a period of 3 years beginning from December 2021 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.

Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is VAT-exempt under Section 109(1)(P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January 01, 2021, the VAT exemption shall only apply to sale of house and lot and other residential dwellingsl valued at P3,199,200.002.

However, the sale of house and lot units in excess: of the 660 house and lot units

ieasing. retail stores, offices, etc. shall be subject to the payment of appropriate taxes under the registered with the BOI, if any, inctuding those units used for commercial purposes such as Tax Code of 1997, as amended.

applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof. The Company is liable, however, for all other applicable taxe's 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 uponr: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 7 202Z

2 As adjusted using the 2010 Consumer Price Index values pursuant to RR No. 8-2021 dated June 11, 2021. K-1 - MDT I Sale of lot only, regardle S of the price, shalf be subject to VAT s B y: HAFIsSAQ. cABreros Depi#y Commissioner Offcer-in-Charge Legal Group': arting January 01, 2021 pursuant to RA No. 10963 0 8 9 8 Commissioner of Internal Revenue CAESAR R. DULAY

page 2 of 2 Bria Homes San Fernando Cste issued_ MAY_.2"T 2022 CTE NO. BOFLEY

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

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

attributable to the revenues generated from the project, Bria Homes San Fernando -- Brgy. Calutut, City of San Fernando, Pampanga, consisting of 660 house and lot units used solely for family home or dwelling purposes located at Brgy. Calulut, City of San Fernando, Pampanga. Such exemption shall not cover revenues from units with selling price exceeding : be sold for more than P Moreover, the 660 housing units covered by Provisional License to Sell No O per house and lot. I shall nct

2.The enterprise shall observe: the following project timetabte:

Total Project Cost Start of Commercial Operations Site Preparation and Development Building/House Construction Milestone December 2021 Investment Cost and Schedule July 2021 -"December 2026 December 202 - December 2026

3 In the computation of the project's ITH, interest iiicome 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. 107083, the Company is required to file its tax

returns and pay its tax liabilities, on or before the deadtine as provided under the Tax 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 be provided under EO No. 226, within the periods prescribed under RA No. 10708's Implementing Rules and R.eguiations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016.

6. The Company shall be constituted as a withholding agent for the government if it acts as employer and any of its employees received conpensation 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 XII1 and Section 57 of the Tax'Code of 1997. as amended. and implemented by 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 Annuai

Information Return under oath, stating its gross income and expenses incurred during the taxable year.

8. 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 ascerlaining 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 Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by Investment

Promotion Agencies.