BIR Ruling No. 262-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE Quezon City

Certificate of Tax Exemption No: 0L-L-0262-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

No. 2019-211 dated October 25, 2019, for a period of 3 years beginning from November 2019 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, housing project, Paragon Village Phase 2, consisting of 621 house and lot units used solely] withholding tax on its income received directly in connection with its economic and low-cost for family home or dwelling purposes, located at Brgys. San Agustin & Cabuco, Trece Martires City, Cavite, a project duly registered with the Board of Investments (BOI) under Registration Taxpayer Identification Number otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B)(2) of This certifies that THE NEW APEC DEVELOPMENT CORPORATION,with , is exempt from income tax and creditable

Revenue Regulations 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. Provided, however,

that beginning January 1, 2021, the VAT exemption shall only apply to sale of house and lot

and other residential dwellings' with selling price of not more than Two Million Pesos

(P2,000,000.00).

The sale of house and lot units in excess of the 621 house and lot units, including those

house and lot units used for commercial purposes such as leasing, retail stores, offices, etc., are

not covered by this Certificate of Tax Exemption and shall be subject to applicable taxes under

the 1997.Tax Code, 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 MAY 2 6 2020 Peesawany

CAESAR R.DULAY

K-1-JAC Commissioner of Internal Revenue 035049

I Sale of lot only, regardless of the price, shall be subject to VAT starting January O1, 2021 pursuant to RA No. 10963.

The New Apec Development Corporation Paragon Village Phase 2 Page 2 of 2 Date issued _MAY 2 6 2020 CTE No. VO-LEH-0262-2020

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, Paragon Village Phase 2 consisting of P2,000,000.00. Moreover, the 621 house and lot units per HLURB License to Sell No. 034853 shall not be sold for more than P1,700,000.00 per house & lot package. Such exemption shall not cover revenues from units with selling price exceeding 621 house and lot units, located at Brgys. San Agustin & Cabuco, Trece Martires City, Cavite.

2 The enterprise shall observe the following project timetable.

Activity Period

Land acquisition January 2015 to July 2015

Secure necessary license/permit/registration August 2015 to September 2019

from the government/training costs Site preparation and development September 2016 to June 30, 2021

Building/House construction August 2016 to September 2023

Start of Commercial Operations November 2019

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

a exceeding PhP2.0M and used solely for family home or dwelling purposes and not for Only income generated from the sale of housing units (Paragon Village Phase 2 Brgys. San Agustin & Cabuco,Trece Martires City, Cavite with selling price not

commercial purposes such as leasing, retail stores, offices, etc. shall be qualified.

b. Interest income from in-house financing shall not be considered as revenues generated

from the registered activity.

Pursuant to Section 4 of Republic Act (RA) No. 107082, 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

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 from the tax base, as may be

provided under E.O. 226, within thirty (30) days from the deadline for filing of tax returns and

payment of taxes.

5. 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 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 amended and implemented by Revenue Regulations (RR) No. 2-98, as amended.

6. 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 Annual

Information Return under bath, stating its gross income and expenses incurred during the

taxable year.

7. 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 incentivesand its tax liability, if any, pursuant to Section 235 of the Tax Code

of 1997, as amended.

f Tax Incentives Administered by Investment Promotion Agencies.

2 An Act Enhancing Transparency in the Management and Accounting of