BIR Ruling No. 407-2021

TER REPUBLIC OF THE PHLIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No:

BOI-LEH - 0 7 - 2 0 2 1

CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN:

known as the "Omnibus Investments Code of 1987 and Section 2.57.5' (B) (2) of Revenue Regulations (RR) Nc.. 2-98, as amended. dwelling purposes, lo cated at Brgy. Santiago, General Trias, Cavite, a project duly registered dated June 28, 2012, for a period of four (4) years beginning from August 2012 or aetual start of commercial operations/selling, whichever is earlier, but in no case earlier than the date of registration of the pr. ject with the BOI, pursuant to Executive Order (EO) No. 226. otherwise income received dir::ctly in connection with its low-cost mass housing project (horizontal), Amaia Scapes Cav ite. consisting of 6662 housing units used solely for"family home or with the Board of Investments (BOI) under Certificate of Registration (COR) No. (TIN) This certifie: that AMAIA LAND CORP.', with Taxpayer Identification Number is exempt from income tax and creditable withholding tax on its

residential dwellings'" w ith selling price of not more than P3,199,200.00.4 01, 2021, the exemption 'from VAT shall only apply to'sale of house and lot and other below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January Moreover, the sale by the Company of residential lot valued at P1,919.500.00 and

the BOI, if any, inc[uding those units used for commercial purposes such as leasing, retail] stores, offices, etc., shiall be subject to the payment of appropriate taxes under the Tax Code of 1997, as amended. However, the sale of housing units in excess of the 666 housing units registered with

applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof. The Company is liabte, however, for all other applicable taxes not discussed above. The grant of iax exemption herein is subject to the compliance with the provisions of

documents as represtnted and submitted. However, if upon investigation, the BIR ascertains that the facts are diff rent, 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_NOV 6 4 2021

N Yeea

K-1-MDT Commissioner of Internal Revenue CAESAR R. DULAY 046864

3 Sale of lot oniy, regardles of the price, shall be subject to VAT starting January 01, 2021 pursuant to Republic Act (RA) 2 Per License to Sell Nos. + As adjusted using the 201 C..nsumer Price Index values per RR No. 8-2021 dated June 11. 2021. Formerly: First Communi iec Realty, Inc. No. 10963. Regulatory Board (HLUR!3) (448 lots/units) and (218 lots/units) both issued by the Housing and Land Use

(Anaia Scapes Cavite) AMALA LAND CORP Date issued: CTE NO.: .BOI-LEH- -2uL

O : THE CERTIFICATE OF TAX EXEMPTIGN TERMS AND CONDITIONS

The exemption fre n income and creditable withholding taxes cover., only income directly attributable to the re enues generated from the project, Amaia Scapes Cavite, consisting of 666 housing units used s. lely for family home or dwelling purposes, located at Brgy. Santiago, General P2,500,000.00. Mor :over, the 666 housing units covered by License to Sell Nos. tots/units) and Trias, Cavite. Such exemption shall not cover revenues from units with selling price exceeding (218 lots/units) shall not be sold for more than P1.250,000.00 per housing : (448

U nit.

2. Tr.e Company is obli jated to comply with the following schedules/sales re venues:

Ye w Tota! 3 2 (No. of Units) Volume 696 144 43 114 (PhP'000) Value

3. In the computation of tae project's ITH, interest income from in-hous. financing shall not be considered as part of the revenues generated from the registered housing project.

4. The Company's entitlenient 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. 107089, the Compaly is required to file its tax returns and pay its tax liabilities, on or before the deadline as provided unger the Tax Code of 1997 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 Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. as amended, using the electronic system for filing and payment of taxes of ithe BIR. It shall file with

6. The Company shall be constituted as a withholding agent for the governm.ent if it acts as employer and any of its employees received compensation income subject to conpensation 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 am ended, and implemented by RR No. 2-98, as amended.

1 The Company is required to file on or before the 15% day of the fourth unth 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 inc arred during the taxable

year.

8. Finally, the Company's books of accounts and other pertinent records shi.il be subject to periodic examination by revenue enforcement officers of this Bureau for the purposc 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.

5 While the company is obligated to construct 65t: housing units, the exemption from incone ..id creditable withholding tax covers only revenues generated from the 666 ho.sing units allowed per HLURB License to S. l1 Nos 448 lots/units)

% An Act Enhancing Transparency in the Managment and Accounting of Tax Incentives Administered by Investment and 1 (218 lots/units).

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