BIR Ruling No. 647-2017

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHH.IPPINES DEPARTMENT OF FINANCE Quezon City

Certificate of Tax Exemption No: 647-2017

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

known as the "Omnibus Investments Code of 1987" and Sec.2.57.5 (B)(2) of RR No. 2-98, as received directly in connection with its economic and low-cost housing project, Camella Koronadal - Brgy. Carpenter Hill, City of Koronadal, South Cotabato consisting of 599 housing units located at Brgy. Carpenter Hill, City of Koronadal, South Cotabato, a project duly registered with the Board of Investments (BOI) under Registration No. March 31, 2015, for a period of 4 years beginning from March 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 amended. This certifies that COMMUNITIES GENERAL SANTOS, INC. with TIN is exempt from income tax and creditable withhoiding tax on its income - dated

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. Moreover, the sale by the Company of residential lot valued at P1,919.500.00 and

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. Thc grant of tax exemption herein is subiect to the compliance with the provisions of

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 -. day of DEC 19 2017

t&G

K-! Commissioner of Internal Revenue CAESAR R. DULAY 011931

Communities General Santos. Inc. Page 2 of 2 Datc issued 12-19-2017 CTE NO. 547-2017

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

1. The exemption from income and creditable withholding taxes covers only income directly

attributable to the revenues generated from the project, Camella Koronadal - Brgy. Carpenter Hill, City of Koronadal, South Cotabato consisting of 599 housing units. located at Brgy. Carpenter Hill, City of Koronadal, South Cotabato.- Moreover, the exemption covered by License to Sell No. for 296 housing units shall not cover revenues from units with selling price exceeding P3,000.000.00 and the 340_housing units covered by License to Sell No. shall not be sold for more than Pl.250,000.00 per house & lot.

2 The Company is obligated to construct and sell 599 housing units based on the following schedules/sales revenues: Total Year 4 1 2 3 (No. of Units) Volume 5 9 156 137 Ios [ 41 Value(Php 000)

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.

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.

St 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

Code, as amended, using the electronic system for filing and payment of taxes of the BIR. It shail 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 the periods prescribed under R.A. 10708's Impleinenting Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016.

6 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 XII1 and Section 57 of the Tax Code of 1997, as amended and implemented by Revenue Regularions (RR) No. 2-98. as amended.

T The Company is required to file on or before the 15th day of the fourth month following the closc 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

: periodi 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 liabitity, if any, pursuant to Section 235 of the Tax Code of 1997, as amended.

An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by investment Promotion Agencies.