BIR Ruling No. 296-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OFTHE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: DO-LEH-0296-2020

CERTIFICATE OF TAXEXEMPTION

TO ALL WHOM IT MAY CONCERN:

withholding tax on its income received directly in connection with its economic and low-cost Identification Number housing project, FCI -- Castillejos Extension, consisting of 57 house and lot units used solely for family home or dwelling purposes, located at Brgy. Del Pilar, Castillejos, Zambales, a project duly registered with the Board of Investments (BOI) under Registration No. dated September 25, 2018, for a period of 3 years beginning from September 2018 to September 2021, pursuant to Executive Order No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations No. 2-98, as This certifies that FIESTA COMMUNITIES INCORPORATED, with Taxpayer is exempt from income tax and creditable

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 57 house and lot units, including those

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 JUN 0 8 2020

Ge

CAESAR R.DULAY

Commissioner of Internal Revenue

K-1-JAC 034110

Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963.

Page 2 of 2 Fiesta Communities, Inc. - FCI Castillejos Extension CTENo.DOL-L-0296-2020 Date issued JUN 0 8 2020

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

1.The exemption from income and creditable withholding taxes covers only income directly of 57 house and lot units, located at Brgy. Del Pilar, Castillejos, Zambales. Such exemption attributable to the revenues generated from the project, FCI - Castillejos Extension consisting

shall not cover revenues from units with selling price exceeding P2.000,000.00.Moreover,the

P1,700,000.00 per house & lot. 57 house and lot units per HLURB License to Sell No. shall not be sold for more than

2. The enterprise shall observe the following project timetable.

Activity Period

Land acquisition January 2013 Secure-necessary license/permit/registration from the government/training costs Site preparation and development January 2016 ~ September 2017 July 2016

Building/House construction August 2016 ~ December 2018

Start of Commercial Operations September 2018

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

a. Only income generated from the sale of house and lot units (FCI - Castillejos

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. Extension, Brgy. Del Pilar, Castillejos, Zambales) with selling price not exceeding

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 provided under E.O. 226, within thirty (30) days from the deadline for filing of tax returns and returns and pay its tax liabilities, on or before the deadline as provided under the 1997 Tax shall file with BOI a complete annual tax incentives report of its income-based tax incentives, Code, as amended, using the electronic system for filing and payment of taxes of the BIR. It VAT and duty exemptions, deductions, credits or exclusions from the tax base, as may be

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 taxes as source as required under Chapter XIII and Section 57 of the Tax Code of 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.

o 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 oath, stating its gross income and expenses incurred during the taxable year.

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 incentives and its tax liability, 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.