BIR Ruling No. 487-2020

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No:

BOI-LEH-087-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that CITYLAND DEVELOPMENT CORPORATION, with

Taxpayers Identification Number (TIN) , is exempt from income tax and

creditable withholding tax on its income received directly in connection with its low-cost mass

housing project, Grand Central Residences Tower 1, EDSA cor. Sultan Street, Barangay Highway Hills, Mandaluyong City, consisting of 776 residential units used solely for family home or dwelling purposes, located at EDSA cor. Sultan Street, Barangay Highway Hills. Mandaluyong Citv, a project duly registered with the Board of Investments (BOI) under Registration No. dated June 16, 2010, for a period of four (4) years beginning from June 2010 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

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 residential 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 of 1997, as amended. Provided, however, that beginning January 01, 2021, the

exemption from VAT shall only apply to sale of house and lot and other residential dwellings

with selling price of not more than P2,000,000.00.

However, the sale of residential units in excess of the 776 residential units registered

with the BOI (per HLURB License to Sell No. the excess is 428 units), as well as the

106 commercial units and 242 parking slots, including those units used for commercial

purposes such as leasing, retail stores, offices, etc., shall be subject to the payment of

appropriate taxes under the National Internal Revenue Code of 1997, as amended.

The grant of tax exemption herein is subject to the compliance with the provisions of

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.

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 of AUG_2 0 2020

aaMa

CAESAR R.DULAY

K-1-LMAT Commissioner of Internal Revenue 036392

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