BIR Ruling No. 341-2022

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: BOJ-LEH t

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

tax on its income received directly in connection with its economic and low-cost housing project, Identification Number This certifies that PHIRST PARK HOMES INCORPORATED, with Taxpayer is exempt from income tax and creditable withholding

PHirst Park Homes -- Pandi Phase 1, consisting of 338 house and lot units used solely for family home or dwelling purposes, located at Brgy. Poblacion, Pandi, Bulacan, a project dulv registered with the Board of Investments (BOI) under Certificate of Registration No. dated December 26, 2019, for a period of four (4) years beginning January 2020 or actual start of commercial operations, whichever is earlier but in no case earlier than the date of registration pursuant to Executive Order (EO) No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98, as amended.

Moreover, the sale by the Company of a 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 exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January 01, 2021, the exemption from VAT shall only apply to sale of house and lot and other residential dwellings' with selling price of not more than P3,199,200.00.2

units registered with the BOI, if any, including those units which shall be used for commercial The sale of house and lot units in excess of the 338 house and lot

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 Tax Code of 1997, 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 : 6 2722

o CAESAR R. DULAY

KI-FR-20-0658 Commissioner of Internal Revenue 052195

1 Sale of lot only, regardless of the price; shall-be subject to VAT starting January 01, 2021 pursuant to RA No. 10963 2 As adjusted using the 2010 Consumer Price Index values per Revenue Regulations No. 8-2021 dated June 11, 2021.

New Developer of Economic and PHirst Park Homes Incorporated CTE No.8O1LEH3.4 f - 2 0 2 2 Date issued JUN 3-0 2022 Low-Cost Housing Project Page 2 of 2

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, PHirst Park Homes - Pandi Phase 1 consisting of 338 house and lot units, located at Brgy. Poblacion, Pandi, Bulacan. Such

Moreover, the 338 house and lot units per HLURB License to Sell No. exemption shall not cover revenues from units with selling price exceeding P shall not be sold for more than f per house & lot package.

2. The Company shall observe the following timetable:

Start of Commercial Operations Land acquisition Site preparation and development Building/House construction Secure necessary license/permit/registration from the government/training costs Activity October 2018 to January 2020 December 20} 8 to March 2025 March 2019 to April 2025 January 2020 to December 2025 January 2020 Period

3 The Company's entitlement to ITH for its BOI-registered project is subject to the compliance with the provisions of the Terms and Conditions of its BOI Registration.

4 Pursuant to Section 4 of Republic Act (RA) No. 107083, the Company is required to file its tax returns and pay its tax liabilities, on or before the deadline as provided under Tax Code of

1997, as amended, using the electronic system for filing and payment of taxes of the BIR. It shall file with RROI 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.

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 at source as required under Chapter XIII and Section 57 of the Tax Code of 1997, as amended, and implemented by 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 oath, 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 incentives and its tax liability, if any, pursuant to Section 235 of the Tax Code of 1997, as amended.

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