BIR Ruling No. 391-2021

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City IDI

Certificate of Tax Exemption No:

BOI - LEH -391-2021

CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN:

known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B) (2) of Revenue 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 (FO) No. 226, otherwise Regulations (RR) No. 2-98, as amended. Pampanga, consisting of 468 housing units used solely for family hom& or dwelling purposes, Iocated at Barangay Calulut, City of San Fernando, Pampanga, a project duly registered with the Board of Investments (BOI) under Certificate of Registration (COR) No. March 11, 2015, for a period of four (4) years beginning from March 2015 or actuai start of income receiveu uirectly in connection with its low-cost mass housin:g project (horizontai), Amaia Scapes San Fernando Sector 1-A -- Barangay Calulut, City of San Fernando, (TIN) This certifies that AMAIA LAND CORP., with Taxpay er Identification Number ", is exempt from income tax and creditable withholding tax on its dated

01, 2021, the exemption from VAT shall only apply to sale of house and "lot and other residential dwellings2 with selling price of not more than P3,199.200.00.3 below, or house and lot and other residentiai dwellings valued at P3.199,200,00 and below, is exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) cf the National Internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, ihat beginning January Moreover, the sale by the Company of residential lot valued at P1,919500.00 and

stores, offices, etc., shall be subject to the payment of appropriate taxes under the Tax Code of the BOI, if any, including those units used for commercial purposes such as leasing, retail 1997, as amended. However, the sale of housing units in excess of the 468 housing units registered with

applicable BIR rules and regulations and the Terms and Conditions sta ted at the back hereof. that the facts are different, then this Certificate shall be considered null and void. documents as represented and submitted. However, if upon investigation, the BIR ascertains The Company is liable, however, for all other applicable taxes not discussed above. This Certificate of Tax Exemption is being issued on the lasis of the facts and The grant of tax exemption herein is subject to the compliance with the provisions of

issued this day of_OCT 1 8 2U2I

C

K-1-MDT Commissioner of Inrernal Revenue CAESAR R. DULAY t - 6 3 6S

3 As adjusted using the 2010 Consumer Price Index values per RR No. 8-2021 dated June 1 i, 2 21. : Sale of iot only, regardless of the price shall be subject to VAT starting January 01, 2021 p.irsuant to Republic Act (RA) I Formerly: First Communities Realty, Inc. No. 10963.

(Amaia Scapes San Fernan (o Sector I-A) AMAIA LAND CORP. Date issued: CTE No.: .BQLLEH.. 3.9.1 -- 2 0 2 OCT 1 8 20Zi

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption from income and creditabie withholding taxes covers only income directiy sold for more than P..250,000.00 per housing unit. attributable to the re enues generated from the project, Amaia Scape: San Fernando Sector 1-A Pampanga. Such exemption shall not cover revenues from units with seiling price exceeding P3.000.000.00. Mortover, the 468 housing units covered by License to Seil No. solely for family hone or dwelling purposes, located at Barangay Calulut, City of San Fernando. -- Barangay Calulut, City of San Fernando, Pampanga, consisting of 468 housing units used shall not be

2 The Company is ot-ligated to construct and sell 468 housing units based 'on the following

schedules/sales revenues:

Y car Total 1 (No. of Units) Volume 210 210 468 1 29 (PhP'OO( Value

3. In the computation of the project's ITH, interest income from in-house financing shall not be considered as part o: the revenues generated from the registered housing project. 4. The Company's en'itlement to ITH for its BOI-registered housing project is subject to the conpliance with the provisions of the Specific Terms and Conditions of its BOI Reg stration.

5 Pursuant to Section + of Republic Act (RA) No. 107084, the Company is required to file its tax

Joint Memorandum 'Circular No. 1-2016 dated September 1, 2016. returns and pay its tax liabilities, on or before the deadline as provided under the Tax (ode of 1997, 226, within the perio.ds prescribed under RA No. 10708's Implementing Rules and Re ulations and BOI a compiete ani ual tax incentives report of its income-based tax incentives, V AT and duty exemptions, deductinns. credits or exclusions from the tax base, as may be provided u.nder EO No. as amended, using th electronic system for filing and payment of taxes of the BIR. It : hall file with

6. The Company shall Fe constituted as a withholding agent for the government if it acts as employer and any of its employ'ees 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 in'plemented by RR No. 2-98. as omended.

7. The Company is required to file on or before the 15th day of the fou th month following the close Information Return :nder oath, stating its gross income and expens :s incurred during the: taxable of its accounting p-riod of a Profit and Loss Statement and Ba'ance Sheet with the Annual year.

8. Finally. the Compary's books of accounts and other pertinent recor ds shall be subject to periodic and its tax liabitity, :f any. pursuant to Section 235 of the Tax Code of 1997, as amended. examination by reve ::ue enforcement officers of this Bureau for the urpose of ascertaining whether it is complying with the conditions under which it has been granted "ax exemption or tax ince ntives

An Act Enhancing Transt :rency in the Management and Accounting of Tax " ncentives Administered by Investmer.: Promotion Agencies.

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