BIR Ruling No. 644-2017

REPUBLIC OF THE PHIIIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE Quezon City

Certificate of Tax Exemption No: 644-2017

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that FIESTA COMMUNITIES, INC. with TIN is exempt from income tax and creditable withhoiding tax on its income reccived directly in connection with its economic and low-cost housing project, Fiesta Communities -- Mexicc (Barangay Sabanilla) - Barangay Sabanilla, Mexico, Pampanga consisting of 1,433 housing units located at Barangay Sabanilla, Mexico, Pampanga. a project duly registered with the Board of Investments (BOI) under Registration No. dated December 29. 2014, for a period of 4 years beginning from January 2015 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 Scc.2.57.5 (B)(2) of 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 VAT-exempt under Section 109(1)(P) of the 1997 Tax Code, as amended.

The grant of tax exemption herein is subject to the compliance with the provisions ot applicable BIR rules and regulations and the Terms and Conditions stated at the back hercof. The Company is liable, however, to ail other applicable taxes not enumerated 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--DEC_19_2017

aun CAESAR R. DULAY Commissioner of Internal Revenue 011924 K -1

Page 2 of 2 Fiesta Communities, Inc. Date issued 12-13-2017 C'TE No. 644-2017

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 -- Mexico (Barangay Sabanilla) - Barangay Sabanilla, Mexico, Pampanga consisting of 1,433 housing units, located at Barangay Sabanilla, Mexico, Pampanga. Such exemption shall not cover revenues from units with selling price exceeding P3.000.000.00.

2. The Company is obligated to construct and sell 1,433 housing units based on the following

schedules/sales revenues:

Year 2 1 (No. of Units) Volume 27 312 Value(Php 000)

Total 3 4 1,433 32 432

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

4. The Company's entitiement 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.

Pursuant to Section 4 of Republic Act (RA) No. 10708', 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 provided under E.O. 226, within thirty (30) days from the deadline for filing of tax returms 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 fron the tax base, as may be and payment of taxes.

6. The Company shall be constituted as a withholding agent for the government if it acts as

withholding taxes as source as required under Chapter X!II and Section 57 of the Tax Code of employer and any of its employees received compensation income subiect to compensation withholding tax, or if it makes payments to individuals or corporations subject to the 1997, as amended and implemented by Revenue Regulations (RR) No. 2-98, as amended.

7. The Company is required to file on or before the 15:h day of the fourth month following the close of its accounting period of a Profit and Loss Statement and Balance Sheet with the the taxable year. Annual Information Return under oath, stating its gross income and expenses incurred during

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 exemption or tax incentives and its tax liability, if any, pursuant to Section 235 of the Tax Code of 1997, as amended. ascertaining whether it is complying with the conditions under which it has heen granted tax