BIR Ruling No. 417-2021

REPUBLIC G. THEY'HILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City 129

Certificate of Tax Exemption No:

BOI-LEH -4 17 - 20 21

CERTIFICATE OF TAX EXEMPTIO

TO ALL WHOM IT MAY CONCERN:

income received directly in connection with its low-cost mass housi.g project (horizontal), Maisac, Mexico, Pampanga, a project duly reaistered with the Board of Investments (BOn) four (4) years beginning from March 2015 or actual start of cominercial 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 (EO) No. 226, otherwise kncwn as"the "Omnibus as amended. Amaia Scapes Pampanga - Barangay Sapang Maisac, Pampanga, consisting of 1,553 housing units used solely for family home or dwelling purposes, located at Barangay Sapang Investments Code of 1987 and Section 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98, under Certificate of Registration (COR) No. (TIN) This certifies that AMAIA LAND CORP.', with Taxpay er Identification Number is exempt from income tax and creditable withholding tax on its 3 dated March l1, 2015, for a period of

residential dwellings2 with selling price of not more than P3,199,200.00.3 below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is 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 hcuse and lot and other exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) cf the National Internal Moreover, the sale by the Company of residential lot valued at P1,919;500.00 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 1,553 housi .g units registered with

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. The grant of tax exemption herein is subject 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 l.asis of the facts and Issued this day of NOV 0 4 2021

K- Commissioner ot' Internal Revenue CAESAR R. DULAY

0468

Sale of iot only, regardless of the price, shall be subject to VAT starting January 01, 20..I p.rsuant to Republic Act (RA) ' Formerl, : First Communities Realty, Inc. 3 As adjusted using the 2010 Consumer Price Index values per RR No. 8-2021 dated June I 1, 2.121. No. 10163.

AMAIA LAND CORP. (Anaia Scapes Pampanga) CTE No.: Date issued: BOI-LEH-4 t : : 2021

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

1. The exemption frof". income and creditable withholding taxes covers only ir.::ome directly

attributable to the re venues generated from the project, Amaia Scapes Pampang: + -- Barangay Sapang Maisac, Mexico, Pampanga, consisting of 1,553 housing units used sc.ely for family home or dwelling purposes, located at Barangay Sapang Maisac, Mexico, Pempanga. Such exemption shall not cover revenues from units with selling price exceeding P3,000,000.00 Moreover. the 1,553 housing units covered by License to Sell No. than P1,250.000.00 per housing unit. : shall not be sold for more

2 The Company is ot.ligated to construct and sell 1,553 housing units based on the following schedules/sales revenues:

Year Total (No. of Units) Volume 1,553 480 200 393 480 {PhP'000) Value

3. In the computation .if the project's ITH, interest income from in-house financing shall not be

considered as part ot 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 compliance with the provisions of the Specific Terms and Conditions of its BOI Re gistration.

5. Pursuant to Section + of Republic Act (RA) No. 107084, the Company is required to file its tax returns and pay its ta: iabilities, on or before the deadline as provided under the Ta': Code of 1997. 226, within the periods prescribed under RA No. 10708's Implementing Rules and Regulations and Joint Memorandum ("ircular No. 1-2016 dated September 1, 2016. as amended, using the: electronic system for filing and payment of taxes ol the BIR. It shall file with BOI a complete annual tax incentives report of its income-based tax ir.centives, VAT and duty exemptions, deductions. credits or exclusions from the tax base, as may be provide ? under EO No

6. The Company shall he constituted as a withholding agent for the government if it 2 cts as employer and any of its empioyees received compensation income subject to compensation * vithholding tax. required under Chap:er XIII and Section 57 of the Tax Code of 1997, as amended, a d implemented or if it makes payments to individuals or corporations subject to the withholding te xes as source as by RR No. 2-98, as amended.

The Company is required to file on or before the 15" day of the fourth m.nth foll. wing the close of its accounting ptriod of a Profit and Loss Statement and Balance Sheet w th the Annual Information Return ::nder oath. stating its gross income and expenses inc :rred dur ng the taxable year.

8 Finally, the Compar y's books of accounts and other pertinent records sha I be subje :t to periodic it is complying with the conditions under which it has been granted tax exei iption or t. .- incentives and its tax liability. "f any, pursuant to Section 235 of the Tax Code of 199' ', as amend -d. examination by revetue enforcement officers of this Bureau for the purpose of ascertai 'Hing whether

An Act Enhancing Transt trer cy in the Management and Accounting of Tax Incentives. Adminjstered by Iivestment Promotion Agencies. PAGE 2 OF 2