BIR Ruling No. 612-2017

BUREAU OF INTERNAL REVENUE RI'PUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE Quezon City

Certificate of Tax Exemption No: 612-^017

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

or actual start of commercial operations/selling, whichever is earlier, but in no case earlier than housing project, Arezzo Place Pasig -- Phase 1 (Giorgio) and Phase 2 (Franceso) consisting No. Company), with Tax Identification Number creditable withholding tax on its income received directly in connection with its Iow-cost mass of 1.350 residential units located at A. Sandoval Ave., Pinagbuhatan. Pasig City and San Juan. the date of registration of the project with the BOI, pursuant to Executive Order (E.O.) No. 226. otherwise known as the "Omnibus Investments Code of 1987" and Sec. 2.57.5 (B)(2) of Revenue Regulations No. 2-98, as amended. Cainta, Rizal, a project duly registered with the Board of Investments (BOI) under Registration This certifies that PHINMA PROPERTY HOLDINGS CORPORATION (the dated December 21, 2012 for a period of 3 years beginning from December 2012 is exempt from income tax and

Moreover, any sale by the Company of 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.

The sale of units (residential and commercial) in excess of the l,350 residential units. as

subject to applicable taxes under the 1997 Tax Code, as amended. well as of the 177 parking slots are not covered by the Certificate of Tax Exemption, hence.

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

as represented and submitted. However, if upon investigation. the BIR ascertains that the facts This Certificate of Tax Exemption is being issued on the basis of the facts and documents

are different. then this Certificate shall be considered null and void.

Issued this. - day ofDFC1 4 2017

wawM CAESAR R. DULAY

K-1-RFR Commissioner of Internal Revenue 011723

Phinma Property Hofdings Corporation CTE NO 612-2017 Page 2 of 2 Date issued

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project. Arezzo Place Pasig - Phase 1 not cover revenues from units with selling price exceeding P3,000.000.00. (Giorgio) and Phase 2 (Franceso), consisting of i.350 residential units, located at A Sandoval Ave., Pinagbuhatan. Pasig City and San Juan, Cainta, Rizal. Such exemption shall

2 The Company is obligated to construct and sell 1,350 low-cost mass housing units based on

the following schedules/sales revenues:

Total Year ? 3 No. of Units. 1,350 630 300 420 Value (PhP)

3. In the computation of the project's ITH, interest income from in-house financing shall not be considered as part of the revenues generated from the registered housing project.

Thc 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.

5. Pursuant to Section 4 of Republic Act (R.A.) No. 10708', the Company is required to file its tax returns and pay its tax liabilities, on or before the deadline as provided under the 1997 Tax Code, as amended, using the electronic system for filing and payment of taxes of the incentives, VAT and duty exemptions, deductions, credits or exclusions from the tax base. as may be provided under E.O. No. 226, within the periods prescribed under R.A. 10708's Implementing Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated BIR. It shall file with BOI a compiete annual tax incentives report of its income-based tax September l. 2016.

6. The Company shall be constituted as a withholding agent for the government if it acts as withholding taxes as source as required under Chapter XIII and Section 57 of the T`ax Code of 1997. as amended and implemented by Revenue Regulations (R.R.) No. 2-98. as amended. employer and any of its employces received compensation income subject to compensation withholding tax, or if it makes payments to individuals or corporations subject to the

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

8. Finally, the Company's books of accounts and other pertinent records shalt be subject to Code of (997, as amended. periodic examination by revenue enforcement officers of this Bureau for the purpose of exemption or tax incentives and its tax liability, if any, pursuant to Section 235 of the Tax ascertaining whether it is complying with the conditions under which it has been granted tax

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