BIR Ruling No. 632-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE Quezon City

Certificate of Tax Exemption No:

BOI-LEH-0632-202

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

period of four (4) years beginning from November 2018 or actual start of commercial project with the BOI, 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 (RR) No. 2-98, as amended. housing project, Lynville Residences Palo Alto Phase 1 - Brgy. Palo Alto, Calamba City, Laguna, consisting of 3522 house and lot units used solely for family home or dwelling purposes, located at Brgy. Palo Alto, Calamba City, Laguna. a project duly registered with the Board of Investments (BOI) under Registration No. operations/selling, whichever is earlier, but in no case earlier than the date of registration of the Identification Number (TIN) withholding tax on its income received directly in connection with its economic and low-cost This certifies that LYNVILLE LAND DEVELOPMENT CORP.1, with Taxpayers is exempt from income tax and creditable dated October 29, 2018, for a

below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is Revenue 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 P2,000,000.00. exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

leasing, retail stores, offices, etc., shall be subject to the payment of appropriate taxes under the National Internal Revenue Code of 1997, as amended. registered with the BOI, if any, including those units used for commercial purposes such as However, the sale of house and lot units in excess of the 352 house and lot units

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 basis of the facts and

Issued this . day of NOV 1 0 20Z0

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K-1 Commissioner of Internal Revenue CAESAR R.DULAY 037685

2 The ManCom, in its meeting on March 9, 2020 and by virtue of Resolution No. 09-18, Series of 2020, noted and confirmed 1 Formerly: Lynville Realty & Development Corporation 3Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to Republic Act (RA) the amendment of its registered capacity from 324 to 352 house and lot units. No. 10963.

LYNVILLE LAND DEVELOPMENT CORPORATION (Lynville Residences Palo Alto Phase 1) Date issued: NOV 1 1 2020 CTE No.: BOI-LEH-0632-2020

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

The exemption from income and creditable withholding taxes covers only income directly Moreover, the 352 house and lot units covered by License to Sell No. more than P1,700,000.00 per house and lot. Brgy. Palo Alto, Calamba City, Laguna, consisting of 352 house and lot units used solely for family home or dwelling purposes, located at Brgy. Palo Alto, Calamba City, Laguna. Such exemption shall not cover revenues from units with selling price exceeding P2,000,000.00. attributable to the revenues generated from the project, Lynville Residences Palo Alto Phase 1 . shall not be sold for

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

a. Only income generated from the sale of housing units (Lynville Residences Palo Alto

purposes such as leasing, retail stores, offices, etc. shall be qualified. Phase 1 - Brgy. Palo Alto, Calamba City, Laguna) with selling price not exceeding Php2.0M and used solely for family home or dwelling purposes and not for commercial

b.Interest income from in-house financing shall not be considered as revenues generated from the registered activity.

3. The Company's entitlement 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 Registration.

4 Pursuant to Section 4 of Republic Act (RA) No. 107084, the Company is required to file its tax

Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. Revenue 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 E.O. 226, within the periods prescribed under RA No. 10708's Implementing returns and pay its tax liabilities, on or before the deadline as provided under the National Internal

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 con 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 National Internal Revenue Code of 1997, as amended, and implemented by Revenue Regulations (RR) No. 2-98, as amended. ompensation withholding tax,

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 year. Information Return under oath, stating its gross income and expenses incurred during the taxable

7.Finally, the Company's books of accounts and other pertinent records shall be subject to periodic and its tax liability, if any, pursuant to Section 235 of the National Internal Revenue Code of 1997, it is complying with the conditions under which it has been granted tax exemption or tax incentives examination by revenue enforcement officers of this Bureau for the purpose of ascertaining whether as amended.

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