BIR Ruling No. 390-2021

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: 31-LFH-90-221

CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN:

as amended. years beginning from December 2020 or actual start of commercial operations/selling. Investments Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations (RR) No. 2-98, housing project (horizontal), Fiesta Communities -- Castillejos Phase 3, consisting of[201 Pilar, Castillejos, Zambales, a project duly registered with the Board of Investments (BOI) under Certificate of Registration No. 2020-234 dated December 18, 2020, for a period pf 3 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 house and lot units used solely for family home or dwelling purposes, located at Brgy.jDel Identification Number withholding tax on its income received directly in connection with its economic and low-cost This certifies that FIESTA COMMUNITIES INCORPORATED, with Taxpayer t. 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 shall only apply to sale of house and lot and other residential dwellings2 with selling price of not more than P3,199,200.00. VAT-exempt under Section 109(1)(P) of the National Internal Revenue Code of 1997 (Tax Code), as amended. Provided, however, that beginning January 1, 2021, the VAT exemption Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

registered with the BOI, if any, including those units used for commercial purposes such as leasing, retail stores, offices, etc., is not covered by this Certificate of Tax Exemption and shall be subject to the payment of applicabie taxes under the Tax Code, as amended. However, the sale of house and lot units in excess of the 201 house and lot units

applicabie 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. 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 The grant of tax exemption herein is subject to the compliance with the provisions of day of_OCT 1 8 t2

ese

K-I-JAC Commissioner of Internal Revenue CAESAR R. DULAY 046375

2 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 1 As adjusted using the 2010 Consumer Price Index values per Revenue Regulation No. 8-2021.

Fiesta Communities Incorporated Page 2 of 2 CTENo.PL1:LUd-3 U-E02t Date issued WeT XZ

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, Fiesta Communities -- Castillejos Tocated at Brgy. Del Pilar, Castillejos, Zambales. Such exemption shall not cover revenues from units with selling price exceeding f2,000,000.00. Moreover, the 201 house and lot units per HLURB License to Sell No. 035065 shall not be sold for more than P1,700,000.00 per house Phase 3 consisting of 201 house and lot units used solely for family home or dwelling purposes.

& lot package. 2. The enterprise shall observe the following project timetable.

Activity Period Land acquisition May 2018

Start of Commercial Operations from the government/training costs Site preparation and development Secure necessary license/permit/registration Building/House construction October 2019 -- September 2023 August 2018 -- December 2019 August 2018 - August 2022 December 2020

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

a Only income generated from the sale of housing units (Fiesta Communities commercial purposes such as leasing, retail stores, offices, etc. shall be qualified. Castillejos Phase 3 -- Brgy. Del Pilar, Castillejos, Zambales) with selling price not exceeding PhP2.0M and used solely for family home or dwelling purposes and not for

b Interest income from in-house financing shall not be considered as revenues generated from the registered activity. 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 deadline as provided under the Tax Code, as amended, using the electronic system for filing and payment of taxes of the BIR. It shali file

with BOI a complete annual tax incentives report of its income-based tax incentives, VATi and dity exemptions, deductions, credits or exclusions from the tax base, as may be provided under EO 226, within the periods prescribed under RA No. 10708's Implementing Rules: and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. 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 taxes as source as required under Chapter XHHI and Section 57 of the Tax Code, as amended and implemented by RR No. 2-98, as amended. withholding tax, or if it makes payments to individuais or corporations subject to the

7. The Company is required to file on or before the 15% 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 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, as amended.