BIR Ruling No. 309-2022

BUREAU OF INTERNAL REVENUE REPUBLICOFTHE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No. BOI-LEH-309-2022

CERTIFICATE OF TAX EXEMPTION

TO WHOM IT MAY CONCERN:

not exceed P Regulations (RR) No.2-98,as amended, provided that the selling price of said housing units does solely for family home or dwelling purposes located at Blumentritt and Misericordia Sts., Naga City,a project dulv registered with the Board of Investments BOI under Certificate of 2022 or actual start of commercial operation/selling, whichever is earlier, but in no case earlier than the date of registration of the project with the BOI, pursuant to Executive Order (EO) No. 226, otherwise known as theOmnibus Investments Code of 1987and Section 2.57.5(B(2) of Revenue creditable withholding tax on its income received directly in connection with its economic and low- cost housing project, Deca Sentrio Midrise Condominium, consisting of 399 housing units used Registration No with Taxpayer Identification Number (TIN) This certifies that NAGA QUEENSTOWN REALTY AND DEVELOPMENT, INC. per housing unit. dated March 10,2022,for a period of 4 years beginning from March is exempt from income tax and

house and lot and other residential dwellings with selling priceof not more than P3,199,200.002. or house and lot and other residential dwellings valued at P3,199,200.00 and below, is VAT-exempt under Section 1091(P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January 1, 2021, the VAT exe mption shall only apply to sale of Moreover, the sale by the Comipany of housing units valued at P1,919,500.00 and below.

units used for commercial purposes such as leasing, retail stores, offices, et-., shall be subject to the applicable taxes under the Tax Code of 1997, as amended. BOI, (per HLURB Region V License to Sell No. The sale, however, of housing units in excess of the 399housing units registered with the the excess is 21 units), including those

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

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 documents as

Issued this day of JUN 2.4 2022

UO

K-1/220639 Commissioner of Internal Revenue CAESAR R.DULAY 051944

1Sale of lot only, regardless of the price, shall be subject to VAT starting January 1, 2021 pursuant to RA No. 10963. 2 As adjusted using the 2010 Consumer price Indexvalues pursuant to RR No.8-221 dated June 11,2021 (

Deca Sentrio Midrise Condominium Page 2 of 2 CTENO.BO-LEH.309-2022 Dateissued JUN 2~4"2022

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, Deca Sntrio Midrise Condominium, consisting of 399 housing units used solely for family home or dwelling purposes located at Blumentritt and Misericordia Sts., Naga City. Such exemption shall not cover revenues from units with selling price exceeding P

2. The company is obligated to construct and sell 399 housing units based on the following milestones

and total investment capital:

Capital Equipment Acquisition Building/House Construction Start of Commercial Operations Site Preparation and Development Total Project Cost Milestone Investment Cost (in PhP) and Schedule September 2018 --December 2018 December 2018-March 2022 March 2022 June 2021

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

a. Only income directly attributable to revenue generated from the sale of housing units (Deca Sentrio Midrise Condominium - Blumentritt and Misericordia Sts., Naga City with selling

price not exceeding PhP2.0M and used solely for family home or dwelling purposes and not for 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 activ'ty.

4.The Company: entitlement to ifH from 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 the Republic Act (RA) No. 10708the Company is required to file its tax

returns and pay their tax liabilities. on or before the deadline as provided under the Tax Code of 1997, 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 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

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 at source as required under Chapter XIII and Section 57 of the Tax Cod of 1997,as amended and implemented by RR No. 2-98, as amended.

7.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 Baiance 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 periodic

examination by revenue enforcement officers of this Bureau for the purpose of ascertaining whether it has been complying with the conditions under which it has been granted tax exemption or tax incentives and its tax liability, if any, pur:ant to Section 235 of the Tax Code of 1997, as amended.

3 An Act Enhanci Transparency in tie Management and Accotnting of Tax Incentives Administered by Investment Promotion Agencies.